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Commonwealth of Kentucky
Radiation Protection Regulatory Guide
Guidance for Industrial Radiography Use
KYREG-IR
Kentucky Department for Public Health
Radiation Health Branch
275 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Phone: (502) 564-3700
http://www.chfs.ky.gov/dph/radioactive.htm
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 2
EXECUTIVE SUMMARY
Kentucky Regulatory Guides (KYREGS) are issued to describe and make available to the applicant or licensee,
acceptable methods of implementing specific parts of Title 902, Kentucky Administrative Regulations,
Chapter 100, Radiology (902 KAR 100), to delineate techniques used by the staff in evaluating past specific
problems or postulated accidents, and to provide guidance to applicants, licensees, or registrants. KYREGS are
not substitutes for 902 KAR 100; therefore, compliance with them is not required. Methods and solutions
different from those set forth in this guide will be acceptable if they provide a basis for the Kentucky
Department for Public Health (KYDPH), Radiation Health Branch (KYDPH), to determine if a radiation
protection program meets the current rule and protects health and safety.
Comments and suggestions for improvements in this KYREG are encouraged at all times and it will be revised,
as appropriate, to accommodate comments and to reflect new information or experience. Comments should be
sent to: Kentucky Department for Public Health, Radiation Health Branch, 275 East Main Street,
Mailstop HS1C-A Frankfort, KY 40621.
Requests for single copies of this guide (which may be reproduced) can be made in writing to Kentucky
Department for Public Health, Radiation Health Branch, 275 East Main Street Mailstop HS1C-A Frankfort, KY
40621. This guide is also available on our website: http://chfs.ky.gov/dph/radioactive.htm
This KYREG, ‘Guidance for Industrial Radiography Use’, has been developed to streamline the application
process for an Industrial Radiography license. A copy of the KYDPH Form RPS-7, ‘Application for a
Radioactive Material License’ is located in Appendix A of this guide.
Appendix C through P provide examples, models and additional information that can be used when
completing the application.
It typically takes 60-90 days for a license to be processed and issued if the application is complete. When
submitting the application be sure to include the appropriate application fee listed in 902 KAR 100:012. Fee
schedule (http://www.lrc.state.ky.us/kar/902/100/012.htm ).
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 3
In summary, the applicant will need to perform the following to submit an application for an Industrial
Radiography license:
Use this regulatory guide to prepare the KYDPH Form RPS-7, ‘Application for a Radioactive Material
License’ (Appendix A).
Complete the KYDPH Form RPS-7, ‘Application for a Radioactive Material License’ (Appendix A). See
‘Contents of Application’ of the guide for additional information.
Include any additional attachments.
All supplemental pages should be on 8 ½” x 11” paper.
Please identify all attachments with the applicant’s name and license number (if a renewal).
Avoid submitting proprietary information unless it is absolutely necessary.
Submit an original signed application along with attachments (if any).
Submit the application fee (for new licenses only).
Retain one copy of the licensee application and attachments (if any) for your future reference. You will
need this information because the license will require that radioactive material be possessed and used in
accordance with statements, representation, and procedures provided in the application and supporting
documentation.
If you have any questions about the application process, please contact this office at (502) 564-3700 Monday
through Friday, 8:00 AM to 4:30 PM.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 4
CONTENTS
Executive Summary ..............................................................................................................................2
Contents ................................................................................................................................................4
List of Appendices ...............................................................................................................................5
List of Tables .......................................................................................................................................6
List of Figures ......................................................................................................................................6
Abbreviations .......................................................................................................................................7
Purpose of Guide...................................................................................................................................8
Licenses.................................................................................................................................................10
The ‘As Low As Reasonably Achievable (ALARA)’ Concept ............................................................11
Who Regulates Facilities in the Commonwealth of Kentucky? ...........................................................12
Management Responsibility .................................................................................................................13
Applicable Rule ...................................................................................................................................14
How to File ...........................................................................................................................................15
Where to File ........................................................................................................................................16
License Fees ..........................................................................................................................................17
Contents of Application
Type of Application .................................................................................................................18
Item 1 Name and Mailing Address of Applicant .....................................................................18
Item 2 Street Address Where Radioactive Material will be Used ...........................................19
Item 3 Telephone Number .......................................................................................................20
Item 4 Person to be Contacted and listed as contact person ....................................................20
Radiation Safety Officer, Radiographers and Radiographer’s Assistants
Item 5 & 13 Training for Radiographers and Radiographer’s Assistants .................................21
Item 6 & 13 Radiation Safety Officer (RSO) .........................................................................23
Radioactive Material
Item 7 Sealed Source Radioactive Material .............................................................................25
Facilities and Equipment
Item 8 Radiation Detection Instruments ...................................................................................28
Item 9 Calibration of Radiation Detection Instruments ............................................................28
Item 10 Personnel Monitoring Devices ....................................................................................29
Item 11 Facilities and Equipment .............................................................................................30
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 5
Radiation Safety Program
Item 12 Radiation Safety Program ...........................................................................................33
Item 12.1 Radiation Safety Program Audit ...........................................................................34
Item 12.2 Termination of Activities ......................................................................................35
Item 12.3 Material Receipt and Accountability .....................................................................35
Item 12.4 Leak Tests ..............................................................................................................36
Item 12.5 Public Dose ............................................................................................................37
Item 12.6 Quarterly Maintenance ..........................................................................................38
Item 12.7 Operating and Emergency Procedures .................................................................39
Item 12.7.1 Handling and Use of Sealed Sources and Radiography Exposure Devices ...40
Item 12.7.2 Methods and Occasions for Conducting Radiation Survey ............................40
Item 12.7.3 Methods for Controlling Access to Radiographic Areas ................................42
Item 12.7.4 Methods and Occasions for Locking and Securing Radiographic Exposure
Devices, Storage Containers, and Sealed Sources .........................................44
Item 12.7.5 Personnel Monitoring and the Use of Personnel Monitoring Equipment ......44
Item 12.7.6 Transporting Sealed Sources to Field Locations, Securing Exposure
Devices and Storage Containers in Vehicles, Posting Vehicles, and
Controlling Sealed Sources During Transportation .......................................45
Item 12.7.7 Daily Inspection and Maintenance of Radiographic Equipment ....................46
Item 12.7.8 Ratemeter Alarms or Off-Scale Dosimeter Readings .....................................47
Item 12.7.9 Procedure for Identifying and Reporting Defects and Non-Compliance .......48
Item 12.7.10 Required Notifications ...................................................................................49
Item 12.7.11 Minimizing Exposure of Persons in the Event of an Accident .....................51
Item 12.7.12 Source Retrieval ...........................................................................................51
Item 12.7.13 Maintenance of Records ................................................................................53
Item 12.8 Minimization of Contamination ........................................................................53
Item 14 Waste Disposal .......................................................................................................54
Fees and Certification
License Fees .............................................................................................................................55
Item 15 Certification ................................................................................................................55
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 6
LIST OF APPENDICES
Appendix A KYDPH Form RPS-7, ‘Application for a Radioactive Material License’ ....................56
Appendix B KYDPH Form RPS-10, ‘Disposition of Radioactive Material’ ...................................59
Appendix C Sample Delegation of Authority to Radiation Safety Officer Letter ...........................61
Appendix D Sample Signature Authorization Letter .......................................................................63
Appendix E Information Needed for Transfer of Control Application ............................................56
Appendix F NRC Regulatory Issue Summary 2005-10,
‘Performance-Based Approach For Associated Equipment in 10 CFR 34.20’ ...........69
Appendix G Radiographer and Radiographer’s Assistant Training .................................................77
Appendix H Six-Month Radiographer/Radiographer’s Assistant Inspection Checklist ..................81
Appendix I Radiation Protection Program Audit ............................................................................83
Appendix J Procedure for Calibrating Survey Instruments ............................................................91
Appendix K Requests to Perform Leak Testing and Sample Analysis .............................................94
Appendix L Guidance for Demonstrating That Individual Members of the Public Will Not
Receive Doses Exceeding the Allowable Limits .........................................................97
Appendix M Information for Applicants to Consider When Developing Procedures for
Operating Radiography Equipment .............................................................................106
Appendix N Transportation ..............................................................................................................109
Appendix O Daily Maintenance Check of Radiographic Equipment ..............................................117
Appendix P Model Emergency Procedure .......................................................................................119
Appendix Q Annual Low Level Waste Reporting Requirements .....................................................122
Appendix R KYDPH Form RPS-12, Transfer of License Control ..................................................123
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 7
LIST OF TABLES
Table 1 Who Regulates the Activity ..........................................................................................12
Table 2 Radiation Safety Officer Duties and Authorities ..........................................................24
Table 3 Industrial Nuclear Model Ir-100 Exposure Maximum Authorization – 120 Ci ...........27
Table 4 Spec Model 150 Exposure Device Maximum Authorization – 150 Ci ........................27
Table 5 Amersham Model 680 System Exposure Device Maximum Authorization – 110 Ci ..27
Table 6 Deleted
Table 7 Occupational Dose Limits For Adults ………………………………………………. 29
Table 8 Surveys Required for Radiographic Operations ...........................................................41
Table 9 Required Notifications .................................................................................................50
Table 10 Calculation Method, Part 1: Hourly and Annual Dose Received from Device 1 .........99
Table 11 Calculation Method, Part 1: Hourly and Annual Dose Received from Device 2 ........100
Table 12 Calculation Method, Part 1: Total Hourly and Annual Dose Received from
Devices 1 and 2 ............................................................................................................100
Table 13 Calculation Method, Part 2: Annual Dose Received from Devices 1 and 2 ................101
Table 14 Calculation Method, Part 3: Annual Dose Received from Devices 1 and 2 ................102
Table 15 Half Value Layers (HVL) for Typical Shielding Materials .........................................102
Table 16 Calculation Method, Part 4: Annual Dose Received from Devices 1 and 2 ................103
Table 17 Combination Measurement – Calculation Method ......................................................104
LIST OF FIGURES
Figure 1 Diagram of a Permanent Radiographic Installation ......................................................31
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 8
ABBREVIATIONS
ALARA as low as reasonably is achievable
ANSI American National Standards Institute
ALI annual limit on intake
Bq Becquerel
CFR Code of Federal Regulations
Ci Curie
cm centimeter
cm2
centimeter squared
cpm counts per minute
COC Certificate of Compliance
DOE United States Department of Energy
DOT United States Department of Transportation
dpm disintegrations per minute
DU Depleted uranium
hr Hour
GM Geiger-Mueller
IN Information Notice
mCi millicurie
mR milliroentgen
mrem Millirem
mSv Millisievert
NARM Naturally-occurring and Accelerator-produced Radioactive Material
NIST National Institute of Standards and Technology
NMSS Office of Nuclear Materials Safety and Safeguards
NRC United States Nuclear Regulatory Commission
NVLAP National Voluntary Laboratory Accreditation Program
OSLD optically stimulated luminescence dosimeter
RG Regulatory Guide
RQ Reportable quantities
RSO Radiation Safety Officer
SI International System of Units (abbreviated SI from the French Le Systeme Internationale
d'Unites)
SSD Sealed Source and Device
SSDR Sealed Source and Device Registry
Sv Sievert
TEDE Total effective dose equivalent
TI Transportation Index
TLD Thermoluminescent dosimeters
KYDPH Kentucky Department of Public Health
Ci microcurie
% percent
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 9
PURPOSE OF GUIDE
This document provides guidance to an applicant in preparing a license application for Industrial Radiography.
It also provides guidance on KYDPH’s criteria for evaluating an Industrial Radiography license application. It
is not intended to address the research and development of radiography devices or associated equipment, or the
commercial aspects of manufacturing, distribution, and service of such devices or equipment. The term
‘radiography’ as used in this guide means an examination of the structure of materials by nondestructive
methods, using ionizing radiation to make radiographic images generally using gamma-emitting radioactive
materials (radioisotopes). The radioisotopes most commonly used for radiography are Iridium-192 and Cobalt-
60; however, other radioisotopes (e.g. Selenium-75 & Californium-252) with unique radiological characteristics
may also be used.
This guide identifies the information needed to complete KYDPH Form RPS-7, ‘Application for a Radioactive
Material License’ (Appendix A).
The format for each item number in this guide is as follows:
Rule - references the requirements from 902 KAR 100. Radiology applicable to the item;
Criteria - outlines the criteria used to judge the adequacy of the applicant's response;
Discussion - provides additional information on the topic sufficient to meet the needs of most readers;
and
Response from Applicant - shows the appropriate item on the application and provides: response(s),
offers the option of an alternative response, or indicates that no response is needed on that topic.
The information submitted in the application must be sufficient to demonstrate that proposed equipment,
facilities, personnel, and procedures are adequate to protect the health and safety of the citizens of the
Commonwealth of Kentucky in accordance with agency guidelines. Submission of incomplete or inadequate
information will result in delays in the approval process for the license. Additional information will be
requested by KYDPH when necessary to ensure that an adequate radiation safety program has been established.
Such requests for additional information will delay completion of the application’s review and may be avoided
by a thorough study of the rule and these instructions prior to submitting the application. As stated in 902 KAR
100:040, Section 3. Filing of Application for a Specific License., if the applicant fails to respond within thirty
(30) days of receipt to a written request for additional information, KYDPH can deny the application or in the
event the license has been issued, suspend, modify, or revoke the license in accordance with 902 KAR 100:170.
Proceedings. (http://www.lrc.state.ky.us/kar/902/100/170.htm )
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 10
902 KAR 100. Radiology requires the applicant and/or licensee to develop, document, and implement
procedures that will ensure compliance with the rule. The appendices describe radiation protection procedures.
Each applicant should read the rule and procedures carefully and then decide if the procedure addresses specific
radiation protection program needs at the applicant’s facility. Applicants may adopt a procedure included in this
KYREG or they may develop their own procedures to comply with the applicable rule.
In this guide, “dose” or “radiation dose” means absorbed dose, dose equivalent, effective dose equivalent,
committed dose equivalent, committed effective dose equivalent, or total effective dose equivalent (TEDE).
These terms are defined in 902 KAR 100:010. Definitions for902 KAR Chapter 100.
(http://www.lrc.state.ky.us/kar/902/100/010.htm). Rem and Sievert (Sv), its SI equivalent (1 rem = 0.01 Sv),
are used to describe units of radiation exposure or dose. These units are used because 902 KAR 100:019.
Standards for protection against radiation. (http://www.lrc.state.ky.us/kar/902/100/019.htm), sets dose limits
in terms of rem, not rad or roentgen. Furthermore, radioactive materials commonly used in medicine emit beta
and photon radiation, for which the quality factor is 1; a useful rule of thumb is an exposure of 1 roentgen is
equivalent to an absorbed dose of 1 rad and dose equivalent of 1 rem.
The KYREG provides the latest guidance and is modeled on the Nuclear Regulatory Commission’s (NRC)
Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Industrial Radiography
Licenses (NUREG-1556, Volume 2) (http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v2/ ).
The KYREG shows the requirements in terms of the 902 KAR 100 and provides a user-friendly format to
assist with the preparation of an Industrial Radiography license application.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 11
LICENSES
Applicants should study this document, related guidance, and all applicable regulations carefully before
completing the KYDPH Form RPS-7‘Application for a Radioactive Material License’. KYDPH expects
licensees to provide requested information on specific aspects of their proposed radiation protection program in
attachments to the application. When necessary, KYDPH may ask the applicant for additional information to
gain reasonable assurance that an adequate radiation protection program has been established.
After a license is issued, the licensee must conduct its program in accordance with the following:
Statements, representations, and procedures contained in the application and in correspondence with
KYDPH;
Terms and conditions of the license; and
902 KAR 100. Radiology.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 12
THE ‘AS LOW AS IS REASONABLY ACHIEVABLE
(ALARA)’ CONCEPT
902 KAR 100:019. Standards for protection against radiation. Section 2. Radiation Protection Programs,
states that “each licensee shall develop, document, and implement a radiation protection program
commensurate with the scope and extent of licensed activities” and “the licensee shall use, to the extent
practical, procedures and engineering controls based upon sound radiation protection principles to achieve
occupational doses and doses to members of the public that are...ALARA.” This section also requires that
licensees review the content of the radiation protection program and its implementation annually.
(http://www.lrc.state.ky.us/kar/902/100/019.htm )
Information directly related to radiation protection standards in 902 KAR 100:019. Standards for protection
against radiation., is contained in:
NRC’s Consolidated Guidance: 10 CFR Part 20 — Standards for Protection Against Radiation
(NUREG-1736) (http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1736/ )’
Applicants should consider the ALARA philosophy detailed in these reports when developing plans to work
with licensed radioactive materials.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 13
WHO REGULATES FACILITIES IN THE
COMMONWEALTH OF KENTUCKY?
In the special situation of work at federally controlled sites in the Commonwealth of Kentucky, it is necessary
to know the jurisdictional status of the land to determine whether the Nuclear Regulatory Commission (NRC) or
KYDPH has regulatory authority. The NRC has regulatory authority over land determined to be under
“exclusive federal jurisdiction”, while KYDPH has jurisdiction over non-exclusive federal jurisdiction land (see
Table 1). Applicants and licensees are responsible for finding out, in advance, the jurisdictional status of the
specific areas where they plan to conduct licensed operations. KYDPH recommends that applicants and
licensees ask their local contacts for the federal agency controlling the site (e.g., contract officer, environmental
health officer, district office staff) to help determine the jurisdictional status of the land and to provide the
information in writing, so that licensees can comply with KYDPH or NRC regulatory requirements, as
appropriate. The following table lists examples of regulatory authority.
Table 1: Who Regulates the Activity?
Applicant and Proposed Location of Work Regulatory Agency
Federal agency regardless of location (except that Department of
Energy [DOE] and, under most circumstances, its prime contractors
are exempt from licensing [10 CFR 30.12])
NRC
Non-federal entity in non-Agreement State, U.S. territory, or
possession NRC
Non-federal entity in Kentucky at non-federally controlled site KYDPH
Non-federal entity in Kentucky at federally-controlled site not
subject to exclusive Federal jurisdiction KYDPH
Non-federal entity in Kentucky at federally-controlled site subject
to exclusive federal jurisdiction NRC
A current list of Agreement States (states that have entered into agreements with the NRC that give them the
authority to license and inspect radioactive material used or possessed within their borders), including names,
addresses, and telephone numbers of responsible officials are maintained by NRC Office of Federal and State
Materials and Environmental Management Programs and is available on their web site http://nrc-stp.ornl.gov/.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 14
MANAGEMENT RESPONSIBILITY
KYDPH endorses the philosophy that effective radiation protection program management is vital to safe
operations that comply with KYDPH regulatory requirements.
"Management" refers to the chief executive officer or other individual having the authority to manage, direct,
or administer the licensee’s activities or that person’s delegate or delegates.
To ensure adequate management involvement, a management representative (i.e., chief executive officer or
delegate) must sign the submitted application acknowledging management's commitments to and responsibility
for the following:
Radiation protection, security, and control of radioactive materials, and compliance with rule;
Knowledge about the contents of the license application;
Compliance with current KYDPH and United States Department of Transportation (US DOT) regulations
and the licensee’s operating and emergency procedures;
Provision of adequate resources (including space, equipment, personnel, time, and, if needed, contractors)
to the radiation protection program to ensure that the public and workers are protected from radiation
hazards;
Appointment of a qualified individual who has agreed in writing to work as the RSO;
Confirming that the RSO has independent authority to stop unsafe operations and will be given sufficient
time to fulfill his/her radiation safety duties and responsibilities;
Ensuring worker audits are conducted at 6-month intervals (may be performed by the RSO);
Ensuring workers have had adequate training;
Reporting equipment failures as required under 902 KAR 100; and
Ensuring current, up-to-date KYDPH and US DOT rules and regulations are available to all employees.
Management may delegate individuals (i.e., an RSO or other designated individual) to submit amendment
requests to KYDPH or make license commitments on their behalf. A Signature Authorization letter must be
completed, signed by management and submitted to KYDPH. A sample Signature Authorization letter has been
included in Appendix D.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 15
APPLICABLE RULE
It is the applicant’s or licensee's responsibility to obtain read and follow 902 KAR 100. Radiology.
The following Parts of 902 KAR 100. Radiology contain requirements applicable to Industrial Radiography
licensees:
902 KAR 100:015. General requirements. (http://www.lrc.state.ky.us/kar/902/100/015.htm)
902 KAR 100:040. General provisions for specific licenses.
(http://www.lrc.state.ky.us/kar/902/100/040.htm)
902 KAR 100:070. Transportation of radioactive material.
(http://www.lrc.state.ky.us/kar/902/100/070.htm)
902 KAR 100:100. Industrial radiography. (http://www.lrc.state.ky.us/kar/902/100/100.htm)
902 KAR 100:165. Notices, reports, and instructions to employees.
(http://www.lrc.state.ky.us/kar/902/100/165.htm)
Requests for single copies of the above documents (which may be reproduced) can be made in writing to:
Kentucky Department for Public Health, Radiation Health Branch, 275 East Main Street, Mailstop HS1C-A
Frankfort, KY 40621 or for an electronic copy go to our web site at: http://chfs.ky.gov/dph/radioactive.htm.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 16
HOW TO FILE
Applicants for a materials license should do the following:
Be sure to use the current guidance from KYDPH in preparing an application. (see “Forms and Guides
section at http://www.chfs.ky.gov/dph/radioactive.htm )
Complete KYDPH Form RPS-7, ‘Application for a Radioactive Material License’ (Appendix A).
For each separate sheet, other than submitted with the application, identify and key it to the item number
on the application, or the topic to which it refers.
Submit all documents, on 8-1/2 x 11 inch paper.
Avoid submitting proprietary information unless it is absolutely necessary.
Submit an original, signed application.
Retain one copy of the license application for your future reference.
Deviations from the suggested wording of responses as shown in this KYREG or submission of
alternative procedures will require a more detailed review.
Note: Personal employee information (i.e.; home address, home telephone number, Social Security Number,
date of birth and radiation dose information) should NOT be submitted unless specifically requested by
KYDPH.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 17
WHERE TO FILE
Applicants wishing to possess or use radioactive material in the Commonwealth of Kentucky are subject to the
requirements of 902 KAR 100. Radiology and must file a license application with:
Kentucky Department for Public Health
Radiation Health Branch
275 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 18
LICENSE FEES
The appropriate fee must accompany each application or license amendment request. Refer to 902 KAR
100:012. Fee schedule. (http://www.lrc.state.ky.us/kar/902/100/012.htm) to determine the amount of the fee.
KYDPH will not issue the new license prior to fee receipt. Once the technical review has begun, no fees will be
refunded. Application fees will be charged regardless of KYDPH’s disposition of an application or the
withdrawal of an application.
Licensees are also subject to annual fees; refer to 902 KAR 100:012. Fee schedule.
(http://www.lrc.state.ky.us/kar/902/100/012.htm)
Direct all questions about KYDPH’s fees to:
Kentucky Department for Public Health
Radiation Health Branch
275 East Main Street
Mailstop HS1C-A
Frankfort, KY 40621
Telephone: (502) 564-3700 8:00 AM – 4:30 PM Monday - Friday
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 19
CONTENTS OF APPLICATION
Type of Application
On the application check the box for a new license or list the license number for renewal, amendment, or
amendment in entirety as appropriate.
Response from Applicant:
New License(1)
Check.______ Amendment in Entirety
(1) of License
No._________________________ Amendment to
(2, 3) License
No._______________________ Renewal of
(2, 3) License
No.______________________
Item 1: Name and Mailing Address of Applicant
List the legal name of the applicant's corporation or other legal entity with direct control over use of the
radioactive material. A division or department within a legal entity may not be a licensee. An individual may
be designated as the applicant only if the individual is acting in a private capacity and the use of the radioactive
material is not connected with employment in a corporation or other legal entity. Provide the mailing address
where correspondence should be sent. A Post Office box number is an acceptable mailing address.
Notify KYDPH of changes in the mailing address.
Response from Applicant:
1. Applicant’s Name and Mailing Address
Note: KYDPH must be notified in advance in the event of change of ownership or control and bankruptcy
proceedings, see below for more details.
Timely Notification of Change of Ownership or Control
Rule: 902 KAR 100:040 Section 11
Criteria: Licensees must provide full information and obtain KYDPH’s written consent prior to transferring
control of the license, or, as some licensees call it, ‘transferring the license’.
Discussion: Changes in ownership may be the results of mergers, contractual agreements, buyouts, or majority
stock transfers. Although it is not KYDPH's intent to interfere with the business decisions of licensees, it is
necessary for licensees to obtain prior KYDPH’s written consent. This is to ensure the following:
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 20
Radioactive materials are possessed, used, or controlled only by persons who have valid license
issued by KYDPH, the NRC, or another Agreement state;
Materials are properly handled and secured;
Persons using these materials are competent and committed to implementing appropriate
radiological controls;
A clear chain of custody is established to identify who is responsible for final disposal of
radiography devices; and
Public health and safety are not compromised by the use of such materials.
Note: Appendix E identifies the information to be provided about transfer of control.
Notification of Bankruptcy Proceedings
Rule: 902 KAR 100:040 Section 4
Criteria: Immediately following filing of voluntary or involuntary petition for bankruptcy for or against a
licensee, the licensee must notify KYDPH in writing, identify the bankruptcy court in which the petition was
field and the date of filing.
Discussion: Even though a licensee may have filed for bankruptcy, the licensee remains responsible for
compliance with all regulatory requirements. KYDPH needs to know when licensees are in bankruptcy
proceedings in order to determine whether all licensed material is accounted for and adequately controlled and
whether there are any public health and safety concerns (e.g., contaminated facility). KYDPH shares the results
of its determinations with other entities involved (e.g., trustees) so that health and safety issues can be resolved
before bankruptcy actions are completed.
Licensees must notify KYDPH immediately of the filing of a bankruptcy petition.
Item 2: Location of Radioactive Material
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Applicants must provide a specific address for each location where radioactive material will be used,
stored, or dispatched.
Discussion: Specify the street address, or other descriptive address (such as on Highway 17, 5 miles east of the
intersection of Highway 17 and State Route 234), city and zip code for each permanent storage or use facility
and field station. A field station is a location where licensed material may be stored or used, and from which
the applicant will dispatch equipment to jobsites. In Kentucky, all field stations must apply for and be granted a
separate specific license. No two field stations can operate under the same specific license unlike in the NRC
and many Agreement States. A Post Office Box address is not acceptable because KYDPH needs a specific
address to allow an inspector to find the use and/or storage location. If devices will NOT be stored at a
dispatch site or field station, indicate this. The applicant should indicate whether a location will be used to
perform radiographic operations, storage of sources and devices or used and stored. The applicant should
indicate if a permanent cell is located at the address. The applicant should also specify that industrial
radiography will be performed at temporary jobsites within the Commonwealth of Kentucky if applicable.
Obtaining a KYDPH license does not relieve a licensee from complying with other applicable federal, state or
local regulations (e.g., local zoning requirements for storage locations).
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 21
Response from Applicant:
2. Street address(es) where radioactive material will be Used or Stored (no P.O. Boxes)
Note: If radiography operations are expected to exceed 180 days at a temporary jobsite, then provide written
notification to KYDPH prior to exceeding the 180 days (a license amendment is not required).
Item 3: Telephone Number
Criteria: List the telephone number at which the applicant can be contacted during normal working hours,
Monday through Friday, 8:00 AM to 4:30 PM. This telephone number will be listed on the license document.
Only one telephone number can be listed on the license.
Discussion: Notify KYDPH if the telephone number changes. This notice is ‘for information only’ and the
change will be processed as a Technical Amendment and it does not require a license amendment fee.
Response from Applicant:
3. Telephone Number
Item 4: Person To Contact Regarding Application
Criteria: Identify the individual who can answer questions regarding the application. This is typically the
proposed RSO or knowledgeable management official. This individual’s name will be listed on the license
document. KYDPH will contact this individual if there are any questions about this application.
Discussion: Notify KYDPH if the contact person changes. This notice is ‘for information only’ and does not
require a license amendment fee. Contact information changes will be processed as Technical Amendments at
no cost to the facility.
Response from Applicant:
4. Person to be contacted and listed as contact person
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 22
Item 5 & 13: Training for Radiographers and Radiographer’s Assistants
Rule: 902 KAR 100:010; 902 KAR 100:040; 902 KAR 100:100
Criteria: Radiographers and radiographer's assistants must have adequate training and experience as outlined
in 902 KAR 100:100 (http://www.lrc.state.ky.us/kar/902/100/100.htm)
Discussion:
A radiographer is a person who performs or personally supervises industrial radiography and is
responsible for ensuring compliance with KYDPH rules and the safe use of radioactive materials.
A certified radiographer is an individual who has been certified by a certifying entity such that
he/she has met established radiation safety, testing, and experience criteria.
A radiographer's assistant is an individual, who under the direct supervision (in the physical
presence) of the radiographer uses radiographic equipment in performing industrial radiographic
operations.
902 KAR 100:100 describes specific training requirements for radiographers and radiographer's assistants and
requires that all radiographers be certified. It also addresses annual refresher training and semiannual field
audits of radiographers and radiographer’s assistants.
Refer to Appendix G as an aid to determining the specific training requirements for radiographers and
radiographer's assistants. The applicant must submit a description of their training program for radiographers
and radiographer’s assistants.
Because 902 KAR 100:100 contains different training requirements for radiographers and radiographer's
assistants, include specific training programs for each. When describing the training programs for these
positions, include the sequence of events from the time of hiring through the designation of individuals as
radiographers or radiographer's assistants. Experienced radiographers who have worked for another licensee
should receive formal instruction similar to that given to prospective radiographer's assistants. This instruction
must include training in your operating and emergency procedures, in the use of your exposure devices and
associated equipment, and in the use of survey meters and other radiation monitoring devices.
Instructors who provide classroom training to individuals in the principles of radiation and radiation safety
should have knowledge and understanding of these principles beyond those obtainable in a course similar to the
one given to prospective radiographers. Individuals who provide instruction in the hands-on use of radiography
equipment should be qualified radiographers with at least one (1) year of experience in performing radiography,
or should possess a thorough understanding of the operation of radiographic equipment (e.g., a manufacturer's
service representative).
An internal inspection program (audit program) of the job performance of each radiographer and radiographer's
assistant ensures that KYDPH’s rules, license requirements, and the licensee's operating and emergency
procedures are followed. The audit must include observation of the performance of each radiographer and
radiographer's assistant during an actual industrial radiographic operation at intervals not to exceed six (6)
months. If a radiographer or radiographer's assistant has not participated in an industrial radiographic operation
for more than six (6) months, the individual must demonstrate knowledge of the training requirements by
practical examination before participating in a radiographic operation. The person conducting internal
inspections should have a minimum of one (1) year actual experience as a radiographer.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 23
The applicant shall:
Submit an outline of the training to be given to prospective radiographer's assistants. Submit your
procedures for experienced radiographers who have worked for another licensee.
Specify the qualifications of your instructors in radiation safety principles and describe their
experience with radiography. If training will be conducted by someone outside the applicant's
organization, identify the course by title and provide the name and address of the company providing
the training.
Describe the field (practical) examination that will be given to radiographer’s assistants. KYDPH
suggests using the checklist in Appendix H as a source of potential areas to review during the field
examination.
Describe the annual refresher training program, including topics to be covered and how the training
will be conducted.
Submit your procedures for verifying and documenting the certification status for verifying that their
certification remains valid. As a minimum your procedures for newly hired, previously certified
individuals should require documentation of your contacting the certifying entity and confirming the
certification. Your procedures should also ensure you are aware of certification expiration dates and
that individuals with expired certifications do not act a radiographers.
Submit a description of your program for inspecting the job performance of each radiographer and
radiographers' assistant at intervals not to exceed six (6) months as described in 902 KAR 100:100
Section 14. (http://www.lrc.state.ky.us/kar/902/100/100.htm)
Response from Applicant:
5. Individual(s) and Title(s) who will use or directly supervise use of radioactive material
RADIOACTIVE MATERIALS SHALL ONLY BE USED BY INDIVIDUALS WHO HAVE MET AND MAINTAINED COMPLIANCE WITH THE TRAINING CRITERIA ESTABLISHED IN 902 KAR 100:100 AND HAVE BEEN APPROVED, IN WRITING, BY THE RADIATION SAFETY OFFICER. THE LICENSEE SHALL MAINTAIN RECORDS OF THE TRAINING RECEIVED BY THE RADIOGRAPHERS AND RADIOGRAPHERS’ ASSISTANTS FOR INSPECTION BY THE CABINET FIVE (5) YEARS FOLLOWING THE LAST USE OF RADIOACTIVE MATERIAL BY THE INDIVIDUALS
13. Training and Experience of Users. Submit the formal training of each individual named in Item 5 and 6 indicating the name of persons or institutions providing the training, duration of training, and when training received in the areas of: A) Principles and practices of radiation protection. B) Radioactivity measurement standardization and monitoring techniques and instruments. C) Mathematics and calculations basic to the use and measurement of radioactivity. D) Biological effects of radiation.
Note: X-ray training by itself will not be considered adequate experience for performing gamma radiography.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 24
Item 6: Radiation Safety Officer (RSO)
Rule: 902 KAR 100:040; 902 KAR 100:100
Criteria: RSOs and potential designees are responsible for ensuring that the licensee's radiation safety program
is implemented in accordance with approved procedures, and must have adequate training and experience.
Discussion: The person responsible for the radiation protection program is called the RSO. KYDPH believes
the RSO is the key to overseeing and ensuring safe operation of the licensee's radiography program on a daily
basis. The RSO needs independent authority to stop operations that he or she considers unsafe. He or she must
have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure
radioactive materials are used in a safe manner. Typical RSO duties are illustrated in Table 2.
The RSO may delegate certain day-to-day tasks of the radiation protection program to other responsible
individuals (potential designees). For example, a large multi-state nondestructive testing company with
multiple Agreement State and NRC licenses may appoint an individual designated as ‘local KY RSOs’ who
assists the Corporate RSO located in another state. The local KY RSO can be responsible for overseeing the
day-to-day activities at the KY field station or KY office. If that is the case, the local KY RSO overseeing the
actual day-to-day operation of the facility will be the person whose name will be listed on the KY specific
license as the RSO and not the Corporate RSO. However, the CRSO may be listed as the contact for the
license. Licensees may also appoint other individuals who may ‘step-in’ as an emergency contact when the
local KY RSO is unavailable. The potential designees do not need to meet the required RSO qualifications.
However, these individuals should be qualified, experienced radiographers who are adequately knowledgeable
of the activities to which they are assigned. Applicants do not have to identify other responsible individuals if
day-to-day tasks, etc. will not be delegated.
KYDPH requires the name of the RSO on the license to ensure that licensee management has identified a
responsible, qualified person and that the named individual knows their designation as RSO. Provide KYDPH
with a copy of an organizational chart showing the RSO and other designated responsible individuals starting at
the top with senior management, to demonstrate they have sufficient independence and direct communication
with responsible management officials. Also show in the organizational chart the position of the senior
management official who signs Item 15 of the ‘Application for a Radioactive Material License’ (Appendix A).
To be considered eligible for the RSO position, an individual must be a qualified radiographer, have a minimum
of 2,000 hours (one-year) of full-time, hands-on field experience as a qualified radiographer, and have formal
training in establishing and maintaining a radiation protection program. This should be a course specifically
designed to provide training in running a radiation safety program. A basic radiation safety course is not
acceptable. While a course particular to industrial radiography would be highly encouraged, this is not
required. Hands-on experience means experience in all areas considered to be directly involved in the
radiography process. This includes taking radiographs, surveying devices, transporting the radiography
equipment to temporary jobsites, posting work sites, radiation area surveillance, and completing and
maintaining records. Excessive time spent in only one or two of these operations (film development and/or area
surveillance) should not be counted toward the 2,000 hours. Experience with radiography using X-rays can be
included; however, the majority of experience should be in isotope radiography.
KYDPH will consider individuals with alternative training and experience as RSOs. For example, a person
certified in health physics by the American Academy of Health Physics (http://www.hps1.org/aahp/) with
previous experience in managing a radiation safety program of comparable size and scope could be considered
on an individual case. The qualifications, training, and experience required of the RSO may vary depending
upon the complexity of the applicant's operations and number of radiography personnel.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 25
Table 2: Radiation Safety Officer Duties and Authorities
Radiation Safety Officer Duties and Authorities
1. Establish and oversee all operating, emergency, and ALARA procedures and review
them regularly.
2. Oversee and approve the training program for radiographic personnel.
3. Ensure required radiation surveys and leak test are performed and documented
including any corrective measures taken.
4. Ensure personnel monitoring devices are calibrated and used properly, and that
records are kept of results and timely notifications are made.
5. Operations are conducted safely and corrective actions are implemented, when
necessary, including terminating operations.
Above all, the RSO is the key to maintaining the radiation safety of the operations to
the workers, the public, and the environment.
Response from Applicant:
6. Radiation Safety Officer (one person)
Training and experience required for each user named in Item 5 and for the Radiation Safety Officer in Item 6. For the RSO, duties and responsibilities of the RSO and updated organizational chart are required and if necessary, a signature authorization form.
The applicant shall also provide the following:
Document that may be incorporated into the radiation safety program which outlines the Duties and
Responsibilities of the RSO as they are stated in 902 KAR 100:100 Section 13(3)(a) through (d).
A Delegation of Authority letter that is compatible with the sample letter provided in Appendix C.
A Signature Authorization letter that is compatible with the sample letter provided in Appendix D.
Note: A Signature Authorization letter is not required for the RSO. However, if senior management does
not grant the RSO Signature Authorization for the license, then a member of senior management must sign
all correspondence with KYDPH including all amendment requests and all license commitments.
Note: It is important to notify KYDPH and obtain a license amendment prior to making changes in the
designation of the RSO responsible for the radiation safety program. If the RSO leaves the organization
before an amendment is approved by KYDPH, senior management is responsible for appointing a potential
designee who meets the RSO qualification requirements and who is, in turn, responsible for ensuring that
the licensee's radiation safety program is implemented in accordance with the license and KYDPH rule. If
the designated RSO’s employment with the company unexpectedly terminated for any reason, KYDPH
must be notified immediately.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 26
Radioactive Material
Item 7: Sealed Source Radioactive Material
Rule: 902 KAR 100:040; 902 KAR 100:058; 902 KAR 100:100
Criteria: Applicants must provide the manufacturer's (or distributor's) name and model number for each
requested source assembly (sealed source), exposure device, and source changer. Licensees will only be
authorized for radiographic exposure devices, source assemblies or sealed sources containing radioactive
material and associated equipment meeting KYDPH performance requirements and specifically approved or
registered by the NRC or another Agreement State. Also, identify any depleted uranium that is used as
shielding material (radiographic exposure devices, source changers and some collimators contain depleted
uranium).
Discussion: The NRC or another Agreement State performs a safety evaluation of radiography source
assemblies (sealed sources) exposure devices and source changers prior to distribution of these sources/devices
to specific licensees. The safety evaluation is documented in a Sealed Source and Device Registration (SSDR)
Certificate issued to the manufacturer (or distributor). Therefore, if the source assemblies, exposure devices, or
source changers are approved for use by the NRC or another Agreement State, the applicant need only note the
manufacturer's (or distributor's) name and model number of the sources/devices in its license application to
demonstrate that the requirements are met.
SSDR Certificates contain sections on "Conditions of Normal Use" and "Limitation and Other Considerations
of Use". These sections may include limitations derived from conditions imposed by the manufacturer or
distributor, by particular conditions of use that would reduce radiation safety of the device, or by circumstances
unique to the sealed source or device. For example, working life of the device or appropriate temperature and
other environmental conditions are specified. Except as specifically approved by KYDPH, licensees are
required to use exposure devices according to their respective SSDR Certificates. Applicants should obtain a
copy of the certificate and review it with the manufacturer, distributor or with KYDPH, to ensure that they
understand and comply with the requirements of the SSDR.
Note: If necessary and manufacturer cannot supply the certificate, SSDR certificates are also available by
calling KYDPH at (502) 564-3700. Unfortunately, the NRC restricts access to their Sealed Source and Device
Registry website (http://nrc-stp.ornl.gov/ssdr.html ) strictly to NRC and Agreement State staff.
Consult with the manufacturer of the associated equipment (i.e., equipment that is used in conjunction with the
exposure device that drives, guides, or comes in contact with the source) to be sure that the associated
equipment is compatible with the sources and devices. Licensees must demonstrate that associated equipment
meets the performance requirements in 902 KAR 100:100 that are equivalent to 10 CFR 34.20. NRC
Regulatory Issue Summary (RIS) 2005-10, ‘Performance-Based Approach For Associated Equipment in 10
CFR 34.20’ (Appendix F) alerts licensees to distinguish between items of equipment that are not. For example,
the portion of the connector that is attached to the end of the control cable is actually a component of the source
assembly and is subject to the safety evaluation that must be completed by the NRC or another Agreement State
before the source assembly may be specifically authorized for use by a licensee. NRC RIS 2005-10 also
contains a number of ways that licensees can demonstrate that their associated equipment meets the
performance requirements stated in 902 KAR 100:100.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 27
Response from Applicant:
7. Licensed Material
Element & Mass
Number
A
Chemical and/or
Physical Form
B
Manufacturer Name & Model Number (if sealed
source)
C
Maximum activity (millicuries) per sealed
source OR maximum activity possessed at any one time
D
Maximum number of sealed source/device
combinations possessed at any one
time E
Describe use of radioactive material (Should be keyed to material in Subitem A above. For specific make & model of sealed source/device combinations in Subitem E above, state maximum number possessed at any one time)
The applicant shall identify by manufacturer’s name and model number the type of sealed source(s) to
be possessed and used as well as the maximum number of those sources possessed at any one time.
The applicant shall identify by manufacturer’s name and model number the type of exposure device(s)
to be possessed and used.
The applicant shall list depleted uranium if it is to be used as shielding in the exposure device and/or
collimator. The maximum amount of depleted uranium to be possessed at any one time shall be
specified by mass (e.g. 999 kg DU).
The applicant shall identify by manufacturer’s name and model number the type of source changer(s) to
be possessed and used.
Note: The following tables list several devices with associated radionuclides and amounts:
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 28
Table 3: Industrial Nuclear Model Ir-100 Exposure Device Maximum Authorization -- 120 Ci
Element Sealed Source Curies Source Changer Meeting
10 CFR 34 Requirements
Maximum
Curies
Authorized
Ir-192
IN Model 32 120 Ci Amersham 550-SU
IN IR-50
120 Ci
120 Ci
Ir-192
IN Model 33 120 Ci Amersham 550 -SU
IN IR-50
120 Ci
120 Ci
Ir-192
Amersham 87703 120 Ci Amersham 550 -SU
Amersham 650L
Amersham 820
Amersham 855
IN IR-50
120 Ci
240 Ci
1,000 Ci
960 Ci
120 Ci
Ir-192
Amersham 87704 120 Ci
Amersham 550 -SU
Amersham 650
Amersham 820
Amersham 855
120 Ci
240 Ci
1,000 Ci
960 Ci
Ir-192
SPEC G-40F
120 Ci
Amersham 550 -SU
SPEC C-1
IN IR-50
120 Ci
150 Ci
120 Ci
Ir-192 SPEC G-40T
120 Ci
Amersham 550 -SU
SPEC C-1
IN IR-50
120 Ci
150 Ci
120 Ci
Table 4: Spec Model 150 Exposure Device Maximum Authorization -- 150 Ci
Element Sealed Source Curies Source Changer Curie
Authorization
Ir-192 SPEC G-60 240 Ci SPEC C-1 150 Ci
Table 5: Amersham Model 680 System Exposure Device Maximum Authorization -- 110 Ci
Element Sealed Source Curies Source Changer Curie
Authorization
Co-60 Amersham A424-
14
110 Ci Amersham 770
Amersham 771
550 Ci
110 Ci
Co-60 Amersham 943 110 Ci Amersham 770
Amersham 771
550 Ci
110 Ci
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 29
Items 8 & 9: Radiation Detection Instruments
Rule: 902 KAR 100:019, 902 KAR 100:040 902 KAR 100:100
Criteria: A radiation survey meter intended for industrial radiography that utilizes sealed radioisotope sources
should be capable of accurately measuring the radiation fields produced by the sealed radiography source
currently in use, and be visually checked for damage and for proper operation with a check source or other
appropriate means, such as an exposure device, before use on each day it is to be used. The survey meter shall
be calibrated at intervals not to exceed six (6) months and after each servicing (except for battery changes).
Written procedures are required for inspection and routine maintenance of the survey meters, which is to be
performed at intervals not to exceed three (3) months or before the first use thereafter to ensure proper
functioning of components.
Discussion: The licensee shall keep an adequate number of appropriate radiation survey instruments that are
both calibrated and operable, at each location where radioactive material is present to make the required
radiation surveys. The instrument shall be capable of measuring a range from 0.02 mSv (2 mrem) per hour
through 10 mSv (1 rem) per hour. Each radiation survey instrument shall be calibrated at intervals not to
exceed six (6) months and after instrument servicing, except for battery changes. Records of survey instrument
calibrations will be retained for a minimum of three (3) years. Records are to be made of equipment problems
and maintenance performed and these shall be retained for three (3) years. At least one calibrated, fully
functional survey meter shall be available for each and every exposure device in use at a temporary job site.
However, a backup second survey meter is recommended should the primary survey meter malfunction.
Response from Applicant:
8. Radiation Detection Instruments
Model
Number Available
Radiation Detected (alpha, beta, gamma, neutron)
Sensitivity Range
9. a) Calibrated by Service Company (Name, Address, and Frequency)
b) Calibrated by Applicant (Attach procedures describing method and standards used and training provided to individuals performing calibration)
Note: For detailed information about survey instrument calibration, refer to ANSI N323-1978, ‘Radiation
Protection Instrumentation Test and Calibration’. Reaffirmed 1993 copies may be obtained from the American
National Standards Institute, 1430 Broadway, New York, NY 10018.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 30
Item 10: Occupational Dosimetry
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must provide to employees dosimetry processing that has been accredited under the
National Voluntary Laboratory Accreditation Program (NVLAP) operated by the National Institute of Standards
and Technology (NIST). A complete listing of NVLAP accredited ionizing radiation dosimetry laboratories can
be found at http://ts.nist.gov/standards/scopes/dosim.htm.
Table 7: Occupational Dose Limits For Adults
Occupational Dose Limits for Adults (12VAC5-481-640)
Body Location Dose (Annual)
Total Effective Dose Equivalent (TEDE) 0.05 Sv (5 Rem)
Dose to the skin of the whole body or any
extremity* 0.5 Sv (50 Rem)
Dose to lens of the eyes 0.15 Sv (15 Rem)
*Extremities includes the arms below the elbows and the legs below the knees
Discussion: The licensee may not permit any individual to act as a radiographer or a radiographer's assistant
unless, at all times during radiographic operations each individual wears, on the trunk of the body between the
neck and the waist, a combination of a direct-reading dosimeter (ion chamber pocket dosimeter or electronic
personal dosimeter), an operating alarming ratemeter, and either a film badge, thermoluminescent dosimeter
(TLD) or optical stimulated luminescent dosimeter (OSLD), or similar approved device. At permanent
radiography installations where other appropriate alarming or warning devices are in routine use, wearing an
alarming ratemeter is not required. The direct-reading pocket dosimeters must have a range from zero to 2 mSv
(200 mrem), must be recharged and re-zeroed at the start of each shift, and must be checked for correct response
to radiation at intervals not to exceed twelve (12) months. Electronic personal dosimeters may only be used in
place of ion-chamber pocket dosimeters and not in place of alarming rate meters. Alarming ratemeters must be
preset to give an alarm signal at a dose rate of 5 Sv/hr (500 mrem/hr) and must be calibrated for correct
response at intervals not to exceed twelve (12) months.
A film badge shall be replaced each month and other personal dosimeters processed and evaluated by an
accredited NVLAP processor shall be replaced at intervals not to exceed three (3) months. However, KYDPH
recommends that all personal dosimeters regardless of type, be replaced at one (1) month intervals for all active
radiographers and assistants.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 31
Response from Applicant:
10. Personal Monitoring Devices
Type Supplier Exchange Frequency
(1) Film Badge (2) TLD (3) OSLD (4) Other (specify)
Monthly Bi-monthly Quarterly Other (specify)
Note: To obtain a copy of the NIST Publication 810, ‘National Voluntary Laboratory Accreditation Program,
1997 Directory’, contact the Superintendent of Documents, U.S. Government Printing Office, Washington, DC
20402-9225. (For information on the program call NIST at 301-975-3679). Also NVLAP maintains a directory
of accredited laboratories on the Internet which is updated quarterly. The URL for NVLAP’s home page on the
internet is http://ts.nist.gov/standards/scopes/dosim.htm.
Item 11: Facilities
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must specifically identify and describe permanent radiographic installations, field stations,
and any other locations where radiography will be conducted.
Discussion: A permanent radiographic installation is an enclosed shielded room, cell, or vault, not located at a
temporary jobsite, in which radiography may be performed. A facility is considered ‘permanent’ if it is
intended to be used for radiography, even if radiography is rarely performed there. The nature of the
installation, rather than the frequency of use, determines a permanent radiographic installation. All
radiographic operations conducted at locations of use authorized on the license must be conducted in a
permanent radiographic installation unless specifically authorized by KYDPH. If licensees need to perform
radiography at their place of business outside of a permanent radiographic installation due to unique
circumstances (the item to be radiographed is too large for the facility), then KYDPH must authorize this
method of use. In this case, two individuals, at least one of who must be a radiographer, must be present
whenever radiographic operations occur outside of a permanent radiographic installation.
The one primary (and perhaps the most important) reason licensees have for conducting radiography in a
permanent radiographic installation is that they can limit access. In order to ensure this control, a permanent
radiographic installation located on the ground, must be enclosed by a minimum of four shielded walls
(otherwise the floor must also be shielded). The use of materials, that do not realistically provide shielding, do
not qualify. Areas outside of the facility generally should qualify as unrestricted areas. While the area outside
of a permanent radiographic installation should qualify as an unrestricted area (i.e., not to exceed 2 mR in one-
hour), the rule does not specify radiation limits in order to allow for design flexibility for moving equipment
into and out of the permanent radiographic installation, or other considerations. If the roof of the installation
does not qualify as a unrestricted area, or if no roof exists, mechanical access restrictions (fence, etc.) must be
utilized and additional administrative controls must be imposed to ensure that unwanted access can be gained
only through extraordinary effort. All entrances into the installation must be interlocked with required control
devices as per 902 KAR 100:100. Unless all entrances are locked, at least one radiographer must be present at
the facility whenever radiography is being performed.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 32
A field station is a facility where licensed material may be stored or used and from which equipment is
dispatched. Radiographic operations may be conducted in a permanent radiographic installation or at the place
of business in the same manner as described above. In KY, all field stations are required to have a separate
specific license authorizing the storage and use of radioactive materials.
A restricted area is an area that licensees limit access for the purpose of protecting individuals from undue risks
from exposure to sources of ionizing radiation. A restricted area cannot include areas used as residential
quarters. Consequently, industrial radiography devices must not be stored in homes, motel rooms or similar
locations.
Requirements for a permanent radiographic installation:
Each access point is equipped with a visible-audible signal system. The visible signal is activated by
radiation whenever the source is exposed. The audible signal will sound if anyone tries to enter the
installation while the source is exposed. The requirement for the visible-audible signal system is in
addition to other measures that may be taken to prevent access to the installation, such as locked
doors.
As an alternative to the visible-audible alarm system, it is acceptable to use a control system that will
reduce the radiation level if the entrance to a high-radiation area is opened while the source is out.
The system must be automatic and independent of radiography personnel action. If this alternative is
planned, provide a description of the system.
Diagram depicting the shielding, layout, and audible-visual alarms. A diagram of the installation is
helpful in evaluating the shielding and determining compliance with rules regarding restricted and
unrestricted areas, location of access points, and locations of audible-visible signals. Figure 1 shows
an example installation diagram.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 33
Figure 1: Diagram of a Permanent Radiographic Installation.
Calculations or survey results of radiation levels: For a determination of installation adequacy,
provide information showing that the radiation level in all directions around the installation,
including the roof, will not exceed a dose of 0.02 mSv (2 mrem) in any one hour. Take into account
the highest quantity of radioactive material that will be used in the installation and any limitations on
source positioning in the installation. Radiation doses in all directions around the installation that
are below 0.02 mSv (2 mrem) in any one-hour are considered acceptable. If the radiation doses will
exceed 0.02 mSv (2 mrem) in any one-hour, then steps should be taken (use lower-activity source,
use collimator, or move setup farther away) to reduce the radiation to the acceptable level.
A radiation level on the roof that exceeds 1.0 mSv (100 mrem) in one hour at 30 cm from the surface
is considered a “High Radiation Area" and requires special precautions to control access to the area.
Licensees should make efforts to lower a radiation level exceeding 1.0 mSv (100 mrem) in any one
hour by using additional shielding, collimators, or other engineering controls. The roof of a fixed
radiography cell is a potentially occupied area, and applicants must demonstrate that no individual
member of the public could receive effective doses in excess of 0.02 mSv (2 mrem) in any one hour
or 1 mSv (100 mrem) in a year.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 34
Provide the following as applicable:
If radiography is planned in a permanent radiography installation or installations (including field
stations with permanent exposure cells), provide the following information for each installation:
An annotated sketch or drawing of the facility and its surroundings. The scale to which the
sketch or drawing is made. The same scale should be used for all sketches and drawings.
The recommended scale is 1/4 inch = 1 foot. Drawings to this scale that do not fit on 8 ½” X
11” paper may be provided as sectional drawings;
The type, thickness and density of shielding materials on all sides, including the floor and the
roof;
The locations of entranceways and other points of access to the facility;
A description of the areas adjacent to the facility and the distance to these areas. Include
information on areas adjacent to, above, and below the facility;
A description of the general location of each proposed permanent installation listed in Item 2
(e.g., located in an industrial park, an office complex, etc.) and its current use. If any
proposed permanent installation is adjacent to a private residence, provide diagrams of the
installation that include the building, the proposed restricted area(s), and adjacent areas,
including above and below the restricted areas. Provide commitments that restricted areas do
not include residential quarters, and explain how radiation levels in unrestricted areas will be
maintained at less than 1 mSv (100 mrem) per year;
A description of the visible-audible signal system or entrance control system and its location.
The results of radiation-level calculations or actual radiation measurements adjacent to,
above, and below the installation. The radiation dose in all directions around the installation,
including the roof, should not exceed 0.02 mSv (2 mrem) in any one hour. Clearly identify
the type of source (isotope), the amount (activity) of radioactive material in the source, and
the position of the source within the installation for the calculations or measurements.
Variances will be considered if construction requirements preclude shielding the roof in order to
meet the requirement not to exceed 0.02 mSv (2 mrem) in any one hour. Provide the following
information to obtain approval for a variance:
Procedures for ensuring that no individual is on the roof or could gain access to the roof
during radiography;
Means of preventing access to the roof;
A commitment that the roof will be posted with "Caution (or Danger) Radiation Area" signs;
Steps taken to minimize radiation on the roof; and
Limitations (if needed) on positioning of sources or type (isotope) and amount of radioactive
material that may be used in the installation to ensure that areas adjacent to, above, and
below the installation will be unrestricted areas during the performance of radiography.
If radiation doses on the radiography installation roof exceed 1.0 mSv (100 mrem) in any one hour,
then provide the following information in addition to the items above to apply for this variance:
A commitment that the roof will be posted with "Caution (or Danger) High Radiation Area"
signs;
Evidence of constant surveillance of the roof by closed circuit TV;
Fluctuation of the dose rate;
A description of a control device that would automatically reduce the radiation level to 1
mSv (100 mrem) in any one hour at 30 cm from the radiation source if someone accesses the
roof; and
A description of a control device that activates a visible-audible signal so that both an
individual accessing the roof and the radiographer on duty are made aware of the entry.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 35
Field Stations:
Describe the storage location(s) at the address listed in Item 4 and submit a diagram showing
where the radiography cameras will be stored at both permanent radiographic installations and
field stations. Indicate whether or not radiography will be performed at the place of business
outside of a permanent radiography installation. If radiography will be performed at a site
outside of a permanent radiography installation, provide a diagram of the location where
radiography may be performed and its surroundings, including a description of adjacent property.
Again, in KY all field stations must apply for and be granted a distinct specific license
authorizing the storage and use and dispatching of radioactive materials.
Response from Applicant:
11. Facilities and Equipment. Describe the facilities, remote handling equipment, shielding, fume hoods, etc. Attach a sketch of the facility indicating the location of any radioactive materials (i.e. fixed gauges, storage areas, etc.).
The applicant shall submit the required information as listed in the section titled ‘Facilities and
Equipment’ of KYREG ‘Guidance for Industrial Radiography Use’.
Note: Certain records described in the rule pertaining to radiation safety may need to be on file at these field
stations and each temporary jobsite.
Radiation Safety Program
Item 12: Radiation Safety Program
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: A radiation protection program must be established and submitted to KYDPH as part of the
application. The program must be commensurate with the scope and extent of activities for the use of licensed
materials in industrial radiography. Each applicant for an industrial radiography license must develop,
document, and implement a radiation protection program containing the following elements:
Steps to keep radiation exposures as low as reasonably achievable (ALARA);
Description of equipment and facilities adequate to protect personnel, the public and the
environment;
Conduct of licensed activities by individuals qualified by training and experience;
Written operating and emergency procedures;
Program to inspect the job performance of radiographic personnel ;
Description of organization structure and individuals responsible for ensuring implementation of
radiation safety program; and
Records management.
Discussion: The specific components of the applicant's radiation safety program are detailed in this guide.
Some topics will not require the applicant to submit information as part of an application, but simply provide
the applicant with guidance to comply with a specific KYDPH requirement.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 36
Item 12.1: Radiation Safety Program Audit
Rule: 902 KAR 100:019, 902 KAR 100:040
Criteria: Licensees must review the content and implementation of their radiation protection programs at least
annually to ensure:
Compliance with KYDPH and DOT requirements, and the terms and conditions of the license;
Occupational doses and doses to members of the public that are ALARA; and
Records of audits and other reviews of program content are maintained for three (3) years.
Discussion: Appendix I contains a suggested annual audit program that is specific to industrial radiography
and is acceptable to KYDPH. All areas indicated in Appendix I may not be applicable to every licensee and
may not need to be addressed during each audit.
Audit records acceptable to KYDPH should contain the following information:
Date of audit;
Name of person(s) who conducted the audit;
Names of persons contacted by the auditor(s);
Areas audited;
Audit findings, and corrective actions; and
Follow-up.
It is essential that once identified, problems be corrected in a timely manner. NRC Information Notice (IN) 96-
28, ‘Suggested Guidance Relating to Development and Implementation of Corrective Action’
(http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1996/in96028.html) provides guidance
on this subject. KYDPH will review the licensee's audit results and determine if corrective actions are
thorough, timely, and sufficient to prevent recurrence. If violations are identified by the licensee and these steps
are taken, KYDPH can exercise discretion and may elect not to cite a violation. KYDPH’s goal is to encourage
prompt identification and prompt comprehensive correction of violations and deficiencies.
Response from Applicant:
The applicant shall submit an annual review policy that is compatible with Appendix I.
Item 12.2: Termination of Activities
Rule: 902 KAR 100:040
Criteria: The licensee must do the following:
Promptly notify KYDPH, in writing of:
A decision to permanently cease licensed activity at the entire site or in any separate building or
outdoor area if it contains residual radioactivity making it unsuitable for release according to
KYDPH requirements;
No principal activities have been conducted at the entire site under the license for a period of
twenty-four (24) months;
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 37
No principal activities have been conducted for a period of twenty-four (24) months in any
separate building or outdoor area if it contains residual radioactivity making it unsuitable for
release according to KYDPH requirements.
Submit a decommissioning plan, if required by 902 KAR 100:042;
Decommissioning, as required by 902 KAR 100:040 and 902 KAR 100:042;
Submit to KYDPH, a completed KYDPH Form ‘RPS-10 Disposition of Radioactive Materials’
(Appendix B) and demonstrate that the premises are suitable for release for unrestricted use (e.g.
results of final survey); and
Before a license is terminated, send the records important to decommissioning to KYDPH as
required by 902 KAR 100:042. If licensed activities are transferred or assigned in accordance with
902 KAR 100:040, transfer records important to decommissioning to the new licensee.
Discussion: For guidance on the disposition of radioactive material, and for guidance on decommissioning
records, see Item 14 ‘Waste Management’.
Response from Applicant:
No response is required from the applicant during the licensing phase.
Item 12.3: Material Receipt and Accountability
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must do the following:
Maintain records of receipt, transfer, and disposal of sources/devices; and
Conduct physical inventories at quarterly intervals [not to exceed three (3) months] to account for all
sources of radiation and for devices, including devices containing depleted uranium;
Discussion: Licensed materials must be tracked from ‘cradle to grave’ in order to ensure accountability;
identify when sources/devices may be lost, stolen, or misplaced; and ensure that the possession limit stated on
the license is not exceeded.
Conduct physical inventories (i.e., locate, verify the presence of the material, and account for it in material
transfer record) at quarterly intervals [not to exceed three (3) months] to account for all sealed sources and
devices containing depleted uranium. Records of such inventories must be retained for three (3) years.
Maintain inventory records that contain the following types of information:
Radionuclide and amount (in units of Bq or curies) of radioactive material in each sealed source;
Manufacturer's name, model number, and serial number of each sealed source;
Manufacturer's name, model number, and serial number of each device containing depleted uranium
or radioactive material;
Location of each sealed source and device;
Date of the inventory; and
Name of individual performing inventory.
‘Cradle to Grave’ accountability refers to maintaining the radioactive material from the moment it becomes a
part of your organization through performing the physical inventories (ensuring the material’s location, etc.)
until it leaves your organization (through transfer, return to manufacturer/distributor, or disposal to properly
licensed facility). It is not enough to simply say you got rid of a sealed source or device, you must have written
proof that another licensed entity took physical possession of that same material.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 38
Response from Applicant:
The applicant shall submit a policy for conducting quarterly inventories including a sample inventory record
sheet which is compatible with the requirements of KYREG Guidance for Industrial Radiography Use Item
12.3 Material Receipt and Accountability.
Item 12.4: Leak Tests
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: KYDPH requires testing to determine whether there is any radioactive leakage from the source or
from devices containing depleted uranium shielding. KYDPH finds testing to be acceptable if it is conducted
by an organization specifically licensed by KYDPH, NRC, or another Agreement State, or conducted in
accordance with procedures approved by KYDPH.
Discussion: Manufacturers, consultants, and other organizations may be authorized by KYDPH, the NRC or
another Agreement State to either perform the entire leak test sequence for other licensees or provide leak test
kits to licensees. In the latter case, the licensee is expected to take the leak test sample according to the device
manufacturer's and the kit supplier's instructions and return it to the kit supplier for evaluation and reporting
results. Licensees may also be authorized by KYDPH to conduct the entire leak test sequence themselves.
Measurement of the leak-test sample is a quantitative analysis requiring that instrumentation used to analyze the
sample be capable of reliably detecting 185 Bq (0.005 microcurie) of radioactivity. In practice, the minimum
detectable activity (MDA) of the instrumentation should be at least one-half of the removable contamination
limit.
Sealed sources containing radioactive material must be leak tested at intervals not to exceed six (6) months and
devices containing depleted uranium tested at intervals not to exceed twelve (12) months.
Response from Applicant:
The Applicant shall submit a policy for conducting leak testing that satisfies the following:
Leak tests will be performed by an organization authorized by KYDPH, the NRC or another Agreement State to
provide leak testing services to other licensees; or by using a leak test kit supplied by an organization licensed
by KYDPH, the NRC or another Agreement State to provide leak test kits to other licensees according to kit
suppliers' instructions.
List the name and license number of organization authorized to perform or analyze leak test (Specify whether
KYDPH, NRC, or another Agreement State):
Note: An alternate organization may be used to perform or analyze leak test, without amending the license,
provided the organization is specifically authorized by KYDPH, the NRC or another Agreement State.
OR
We will perform our own leak testing and sample analysis. We will follow the procedures in Appendix K of
KYREG ‘Guidance for Industrial Radiography Use’.
OR
We will submit alternative procedures. (Procedures are attached)
Note: Requests for authorization to perform leak testing and sample analysis will be reviewed on a case-by-case basis and,
if approved, KYDPH staff will authorize via a license condition.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 39
Item 12.5: Public Dose
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must do the following:
Ensure that radiography devices will be used, transported, and stored in such a way that members of
the public will not receive more than 1 mSv (100 mrem) in a year, and the dose from licensed
operations in any unrestricted area will not exceed 0.02 mSv (2 mrem) in any one hour; and
Control and maintain constant surveillance over devices that are not in storage and secure stored
devices from unauthorized removal or use.
Discussion: Operating and emergency procedures that address security and surveillance should be sufficient to
limit exposure of the public during use and after accidents. Public dose is controlled, in part, by ensuring that
devices not in use are stored securely (e.g., stored in a locked area) to prevent unauthorized access or use. If
devices are not in storage, then authorized users must maintain constant control and direct visual surveillance.
Public dose is also affected by the choice of the permanent radiographic installation and storage locations and
conditions. An example of a properly stored device would be a locked room a sufficient distance from any
individual, especially personnel. Use of area monitors such as a TLD or OSLD is an acceptable means of
demonstrating compliance with the annual limit of 1 mSv (100 mrem) in unrestricted areas.
Use the concepts of time, distance, and shielding when choosing a permanent radiographic installation or
storage location. Decreasing the time spent near radiographic operations, increasing the distance of the device
from occupied locations, using shielding material (i.e., high density concrete, solid block, or lead sheets), and
implementing conservative operating procedures (i.e., use of collimators or limiting the direction of exposures
towards the floor) will reduce the radiation exposure of personnel and members of the public. Alternatively, the
remote location of and access to a permanent radiographic installation could prevent members of the public
from receiving 1 mSv (100 mrem) in a year.
If, after an initial evaluation, a licensee makes changes affecting the permanent radiographic installation storage
area (e.g., changing the location of devices within the storage area, removing shielding, adding devices,
changing the occupancy of adjacent areas, moving the storage area to a new location), then the licensee must
perform a new evaluation to ensure that the public dose limits are not exceeded and devices are properly
secured. A detailed sketch or drawing of the storage area describing the specific changes made should also be
submitted to KYDPH for review.
Response from Applicant:
No response is required, in this license application, however the licensee’s evaluation of public dose will be
examined during an inspection.
Note: Appendix L provides additional information for determining that radiation doses for other licensee
personnel and members of the public will not be exceed allowable limits.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 40
Item 12.6: Quarterly Maintenance
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: The licensee shall have written procedures for inspecting and maintaining radiographic exposure
devices, source changers, associated equipment, transport and storage containers, and survey instruments.
Inspection and maintenance must be conducted at intervals not to exceed every three (3) months, or before the
first use thereafter, to ensure the proper functioning of components important to safety. The licensee must also
have procedures necessary to maintain the Type B packaging used to transport radioactive materials, ensure that
Type B packages are shipped properly, and maintain Type B packages in accordance with the Certificate of
Compliance (COC) issued by NRC or other agencies approving such transport packages.
If equipment problems are found, the equipment must be withdrawn from service until repaired, records are
required.
Discussion: These procedures are intended to allow the licensee’s staff to evaluate equipment used in
radiography for safe continued use, to provide a record of this evaluation, and to guide the staff in maintenance.
Equipment found to be unsuitable for service must be withdrawn until repaired and an evaluation for return to
service is made. These procedures may be based on the manufacturer’s recommendations. The procedures are
to be specific to the equipment. For example, radiography drive cable assemblies should be cleaned and
lubricated (when operationally appropriate) in accordance with the recommendations of the equipment
manufacturer or the cable manufacturer or alternatively, with any lubrication and cleaning recommendations
established by the industrial radiography community.
Procedures are also required for Type B packaging used to transport radioactive materials. These procedures
are to be used for shipping and maintenance, and may be properly drawn from the manufacturer’s procedures
and information submitted as a basis for the COC or other transport package approval. COC’s for many Type B
packages can be found on the U.S. Department of Energy RAMPAC website at http://rampac.energy.gov/ .
Response from Applicant:
The Applicant shall include procedures for accomplishing quarterly maintenance. These procedures may be
submitted as part of the operating and emergency procedures.
AND
The applicant shall provide a written commitment to the following: before using a new sealed source/device
combination, we will have written inspection and maintenance procedures that address the use of new
equipment as a Type B transport package. In addition, we will provide training to radiographic personnel
before using a new sealed source/device combination
Operating and Emergency Procedures
Item 12.7: Operating and Emergency Procedures
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Operating and emergency procedures must be established and submitted to KYDPH as part of the
application package. In addition, if radiographers will perform other operations such as source exchange, leak-
testing, and quarterly [not to exceed three (3) months] inspection and maintenance of equipment, appropriate
procedures and instructions for these operations should be included in the operating and emergency procedures.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 41
Each licensee must develop, implement, and maintain operating and emergency procedures containing the
following elements:
Instructions for maintaining security during storage and transportation;
Instructions to keep radiography devices under control and immediate surveillance during use;
Steps to take to keep radiation exposures ALARA;
Steps to maintain accountability during use;
Steps to control access to work sites;
Use of personnel monitoring and radiation survey equipment;
Instruction for packaging and transporting licensed material; and
Steps to take and whom to contact when an emergency occurs.
Discussion: The purpose of operating and emergency procedures is to provide radiography personnel with
specific guidance for all operations they will perform. These topics should be included in the operating and
emergency procedures and need not be presented in order of importance. A sequential set of procedures and
instructions from the beginning to the end of the workday is an acceptable format. Instructions for non-routine
operations, for example, quarterly [not to exceed three (3) months] inspection and maintenance or instrument
calibration, may be included as separate appendices.
It is not necessary for operating and emergency procedures to be specific to a particular make and model of
exposure device, source exchanger, or survey instrument. Procedures submitted to KYDPH should provide
sufficient guidance and instruction for each specific type of device. For example, you may submit a single
operating procedure for crank-out regardless of the manufacturer and/or a single operating procedure for
pipeliner exposure devices regardless of manufacturer.
Applicants who plan to conduct lay-barge, offshore platform, or underwater radiography are required to have
their procedures approved by KYDPH. If you plan to conduct lay-barge, offshore platform or underwater
radiography, your radiation safety program will be reviewed to assure that it contains procedures that
specifically address:
Transport of licensed material;
Storage facilities for licensed material;
Methods for restricting access to radiation areas;
Radiation safety procedures and radiographer responsibilities unique to lay-barge, offshore platform,
or underwater radiography;
Radiographic equipment and radiation safety procedures unique to underwater radiography;
Methods appropriate for use of equipment in water environments;
Applicable inspection and maintenance procedures unique to lay-barge, offshore platform, or
underwater radiography equipment; and
Emergency procedures unique to lay-barge, offshore platform, or underwater radiography.
Operating and emergency procedures must be submitted to KYDPH for review.
Note that providing specific operating and emergency procedures for a particular manufacturer’s make and
model number will require an amendment to the license to obtain KYDPH’s authorization for a new sealed
source/device combination.
Response from Applicant:
The Applicant shall submit operating and emergency procedures to KYDPH for review.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 42
Item 12.7.1: Handling and Use of Sealed Sources and Radiography Exposure Devices
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees need to establish operating and emergency procedures.
Discussion: There are two types of devices normally used for radiography, crankout, and pipeliner. There
should be separate instructions for each type of device. Separate instructions are not necessary for each
different model of a given type of device since the operation of each type is essentially the same regardless of
the manufacturer. Some applicants may choose to use one basic instruction for all crankout devices; others may
choose to have separate instructions for each model. Either approach is acceptable.
Specific procedures should be required for performing source exchanges, including those at temporary jobsites,
field stations, and in a permanent radiographic installation. The procedures should contain warnings of areas of
concern during source exchanges. Recent incidents of sources becoming dislodged from the shielded position
indicate the importance of training personnel in the appropriate techniques. Procedures should require the use
of survey instruments, dosimetry, and for conducting surveys during and after movement of sources.
Response from Applicant:
The applicant shall submit the following:
Step-by-step instructions for using each type of radiographic devices;
Instructions for performing source exchanges; and
Instructions for crankout devices should be separate from those for pipeliner devices.
Note: Manufacturers' manuals and similar documents should not be incorporated into the procedures, rather,
information should be extracted from them and paraphrased.
Appendix M provides information for applicants to consider when developing their procedures for operating
radiography equipment.
Item 12.7.2: Methods and Occasions for Conducting Radiation Surveys
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Perform radiation surveys during use, movement, and storage of licensed material to ensure its safe
use and comply with regulatory requirements.
Discussion: In general, surveys need to be made whenever a source is manipulated or moved. Surveys should
be made with a radiation survey instrument calibrated in accordance with 902 KAR 100. The following table
provides examples of surveys, made during radiographic and associated operations that should be included in
the operating and emergency procedures.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 43
Table 8: Surveys Required for Radiographic Operations
Type of Radiation Survey Frequency Requirement
Boundary of restricted area at temporary jobsite
does not exceed 0.02 mSv (2 mrem) in any one
hour
During the first exposure for
each set up of radiographic
device
902 KAR 100:019
Unrestricted area in vicinity of permanent
radiographic installation or storage area does not
exceed 1 mSv (100 mrem) per year
At intervals not to exceed twelve
(12) months
902 KAR 100:019
External radiation levels when a package is
received and opened Each receipt of package 902 KAR 100:070
Exposure rate does not exceed 2 mSv/hr (200
mrem/hr) on surface and 0.1 mSv/hr (10
mrem/hr) at one meter
Each installation of new source
in exposure device
902 KAR 100:070
Exposure rate does not exceed 2 millisieverts
(200 millirem) per hour at any exterior surface,
and 0.1 millisieverts (10 millirem) per hour at 1
meter from any exterior surface with the sealed
source in the shielded position.
Each installation of new source
in a storage container or source
changer 902 KAR 100:070
Removable contamination level for leak tests of
sealed sources does not exceed 185 Bq (0.005
microcuries)
At intervals not to exceed six (6)
months
902 KAR 100:100
Removable contamination level for leak test of
S-tube of exposures device does not exceed 185
Bq (0.005 microcuries) of DU
At intervals not to exceed twelve
(12) months
902 KAR 100:100
Confirm source has returned to a shielded
position
After every radiographic
exposure 902 KAR 100:100
Confirm source is in shielded position
After every source exchange or
exposure device is placed in
storage 902 KAR 100:100
Exposure rates meet labeling of package (i.e.,
Yellow II) and determine Transportation Index
Every movement of licensed
material on public roads
902 KAR 100:070
Exposure rates in and around vehicle do not
exceed 0.002 mSv/hr (2 mrem/hr) in driver's seat,
2 mSv/hr (200 mrem/hr) on surface and 0.1
mSv/hr (10 mrem/hr) at 2 meters from vehicle
Every movement of a package
labeled Yellow III
902 KAR 100:070
Response from Applicant:
The Applicant shall include in the operating and emergency procedures all surveys as described in the section
titled ‘Methods And Occasions For Conducting Radiation Surveys’ in KYREG ‘Guidance for Industrial
Radiography Use’.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 44
Item 12.7.3: Methods for Controlling Access to Radiographic Areas
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Each licensee must control access to areas where licensed material is either used or stored to prevent
the unnecessary exposure of members of the public. This can be achieved through the use of posting, by
locking devices and areas where licensed materials are stored, and by maintaining constant control and
continuous surveillance of areas where radiographic operations are conducted. Operating and emergency
procedures should include steps for radiographic personnel to ensure that access to licensed materials is
controlled for the types of operations that will be performed.
Discussion:
1. Field/Temporary Jobsites
When radiographic operations are performed outside a permanent radiographic installation, at least two
qualified radiographic personnel must be present. At least one of the individuals must be a radiographer; the
other may be another radiographer or a radiographer's assistant. Both individuals must maintain constant visual
surveillance of the operations to prevent unauthorized entry to the restricted area. Operating procedures must
comply with the two-man rule for radiographic operations at any locations other than permanent radiographic
facilities.
Radiographic personnel are required to maintain continuous direct visual surveillance of operations to protect
against unauthorized entry to the high radiation area during radiographic operations. Radiographic personnel
should be instructed to keep the perimeter of the restricted area under continuous surveillance to prevent
unnecessary exposure of individuals. Operating procedures should specify steps for responding to unauthorized
entry to the restricted area. For example, personnel should be instructed to terminate the radiographic exposure
immediately, before confronting the person who entered the restricted area.
All areas where radiographic operations are conducted require posting of the radiation areas and the high
radiation areas. It is acceptable to post the perimeter of the restricted area rather than the perimeter of the
radiation area. Personnel should be instructed to post "Caution Radiation Area" signs at the point where
radiation levels have been calculated to reach 0.02 mSv (2 mrem) in any one hour. A confirming survey during
to the first exposure of the source should be conducted to confirm the location of the boundary and any
necessary adjustments should be made.
The perimeter of the high radiation area must be posted with a "Caution (or Danger) High Radiation Area"
sign(s) at the point where radiation levels have been calculated to reach 1 mSv (100 mrem) in any one hour. A
confirming survey of the high radiation area perimeter should not be conducted, since such a survey could lead
to unnecessary exposure of personnel.
Surveillance of the restricted area at facilities with multiple levels and multiple access points, or where
members of the public are close to the radiographic operations (e.g., boilers, commercial manufacturing plants,
or power plants during outages) can usually be performed only when more than two radiographic personnel are
assigned to the job. Operating procedures and instruction to personnel should include specific steps for these
circumstances to ensure that access into the restricted area is properly controlled. Adequate control of the
restricted area at with multiple levels would require several personnel and many postings. These special
instructions may include the use of additional personnel to assist radiographic personnel in controlling access
into the restricted area, providing instruction to other workers in the area, or making announcements over the
public address system before and during radiographic operations.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 45
2. Permanent Radiographic Installations
For permanent radiographic installations, instruct personnel about posting each entrance to the facility with a
"Caution (or Danger) High Radiation Area" sign(s), and provide procedures to ensure that the visible-audible
signal system is operable. The operability of the visible-audible system must be checked daily before beginning
radiographic operations. The following procedures may be used:
Expose a radiation source in the permanent installation with all entrances closed;
Determine that each visible signal in and outside the installation is functional;
Open the door to each entrance into the installation to activate the audible alarm;
Close the entrance and confirm that the alarm stops. If the installation has more than one entrance,
only one entrance should be tested at a time; and
Record results of test.
In the event that an entrance control device or an alarm fails to operate properly at the permanent radiographic
installation, the installation may continue to operate for up to seven (7) days while the defective equipment is
fixed, provided that:
The entrance control device is labeled as defective;
Radiography personnel maintain continuous, direct, visual surveillance of access installation points;
and
Radiography personnel use an alarming rate meter.
3. Storage Areas
Radiographic equipment containing licensed material stored in controlled or unrestricted areas must be secured
from unauthorized removal or access. Operating procedures should specify how stored licensed material should
be secured and who is authorized access to licensed material.
A vehicle used to transport licensed material can also be used for storage at locations such as temporary jobsites
or overnight lodging. If the applicant plans to use vehicles for storage, there should be procedures and
instructions to personnel about proper posting of the vehicle. A physical survey should be performed to confirm
that the area around the storage facility is an unrestricted area. Radiation levels may not exceed 0.02 mSv/hr (2
mrem/hr) at 45 cm (18 inches) from any external surface of the vehicle and the vehicle shall be locked when it
is used for storage.
Radiographic equipment stored at temporary jobsites must be secured at a location that prevents access by
unauthorized personnel. This usually requires that the equipment be locked in a heavy duty storage container or
cabinet or other secure area where key access is controlled by site management and radiographic personnel. It
is not acceptable for a device to be chained to a post and left unattended at the place of use during lunch, breaks,
or after hours. Storage of exposure devices at a private residence is unacceptable unless it has been identified
and approved in a license.
Response from Applicant:
The Applicant shall include procedures to control access to radiographic operations and storage areas in the
operating and emergency procedures.
Note: All regulatory criteria applying to your normal place of business for conducting industrial radiography
operations also apply to the location in which you store at your radiographic equipment at a temporary jobsite or
an approved private residence. You must specify this storage location in your license application.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 46
Item 12.7.4: Methods And Occasions For Locking And Securing Radiographic Exposure
Devices, Storage Containers, and Sealed Sources
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: 902 KAR 100:100 requires locking and securing radiographic equipment to protect the public and
radiographers from an inadvertent exposure to radiation.
Discussion: All radiographic devices, i.e., gamma cameras, sealed source storage containers, and source
changers are required to have a lock or outer-locked container to maintain the sealed source in its shielded
position. During radiographic operations the source must automatically be secured in the shielded position each
time the source is returned. Radiographers must not attempt to circumvent the automatic securing features or
tamper with the safety features of radiographic devices. If a radiographer had to leave an exposure device at a
temporary jobsite, it would have to be secured against unauthorized removal or tampering by using the lock on
the device and then locking it in an available space such as a shed, room, etc. Likewise, while in storage being
transported to and from the temporary jobsite, the radiographer would ensure the lock is on the device and then
lock the device in the trailer, etc. All radiographic devices must have two independent physical controls that
form tangible barriers to secure the material from unauthorized removal when the device is not under direct
control and constant surveillance by the licensee both in storage and during transportation not including the lock
on the device. Radiographers and/or radiographer’s assistants must ensure that the exposure device and/or
storage or source containers are maintained locked (and if key locked, with the key removed at all times) when
they are not under the direct supervision of the radiographer or the radiographer's assistant, except at permanent
radiographic installations.
Response from Applicant:
The Applicant shall include procedures for locking and securing radiographic equipment in the operating and
emergency procedures
12.7.5: Personnel Monitoring and the Use of Personnel Monitoring Equipment
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Provide procedures for appropriate use of personnel monitoring equipment.
Discussion: All radiographers or radiographer’s assistants are required to wear on the trunk of their body:
Direct-reading dosimeters;
Film badges, TLDs, OSLDs or similar devices; and
Alarming ratemeters when they are engaged in radiographic field operations.
Film badges, TLDs, OSLDs or similar devices must be assigned to and worn by only one individual. To ensure
full-scale reading capability, direct reading dosimeters such as pencil (pocket) dosimeters or electronic personal
dosimeters must be recharged or reset at the start of each shift so that the dosimeters will be capable of reading
the full scale. Personnel should be instructed that direct reading dosimeters must be read and recorded at the
beginning and end of each shift. Proper operation of alarming ratemeters must be checked each day before use
to ensure that the alarm functions properly. The manufacturer's recommended procedures should be followed.
All radiographers or radiographer’s assistants are required to wear alarming ratemeters except at permanent
radiographic facilities where other appropriate alarm or warning devices (e.g., visible and audible alarms) are in
routine use and are operable. Include instructions about how and where dosimetry devices are to be stored
when not in use. The storage place should be dry, radiation free, and cool so that the devices will not be
affected by adverse environmental conditions.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 47
Response from Applicant:
The applicant shall include instructions for proper use of personnel monitoring equipment in the operating and
emergency procedures
Note: It is good practice to check the dosimeter periodically during the work shift.
Item 12.7.6: Transporting Sealed Sources To Field Locations, Securing Exposure Devices
And Storage Containers In Vehicles, Posting Vehicles, And Controlling Sealed Sources
During Transportation
Rule: 902 KAR 100:040, 902 KAR 100:070 902 KAR 100, 49 CFR Parts 171-178
Criteria: Licensees must develop, implement, and maintain procedures for transporting radioactive material to
ensure compliance with DOT regulations.
Discussion: During an inspection, KYDPH uses the provisions of 902 KAR 100:070 which incorporates the
requirements of 49 CFR, to examine and enforce transportation requirements applicable to radiography
licensees. Appendix N contains: 1) a list of major DOT regulations applicable to transporting radiographic
devices; 2) a condensed summary of KYDPH/DOT requirements; and 3) two sample shipping papers, the
second of which may be more useful for multiple-use, temporary jobsite activities.
Instructions to personnel should not reference KYDPH/DOT requirements. Information should be extracted,
paraphrased and placed into the instructions so that personnel know exactly what they are expected to do. The
following items should be covered in instructions to personnel:
Labeling containers appropriately (i.e., when to use labels Radioactive White I, Radioactive Yellow
II, or Radioactive Yellow III);
Securing the exposure device or storage container within the transporting vehicle. Two independent
physical controls that form tangible barriers to secure the material from unauthorized removal shall
be used when the device is not under direct control and constant surveillance by the licensee. The
instructions should specify how to prevent the package from moving during transport;
Preparation of shipping papers. The instructions should specify that the shipping papers must be
completed before transporting the licensed material and must be accessible in the driver's
compartment at all times. Appendix N contains examples of shipping papers for transporting
radiographic exposure devices;
Placarding both sides, the front, and the back of the vehicle with "RADIOACTIVE" placards if the
package being transported requires a Radioactive Yellow III label. If the vehicle requires placarding
and the package radiation levels exceed 2 mSv/hr (200 mrem/hr) or the transport index exceeds 10,
exterior surfaces and passenger compartment of the vehicle must be surveyed to ensure that the
radiation levels do not exceed 0.02 mSv/hr (2 mrem/hr) from any exterior surface and 0.02 mSv/hr
(2 mrem/hr) in the passenger compartment. Include instructions to personnel on the measures to
take if the radiation level exceeds 0.02 mSv/hr (2 mrem/hr) in the passenger compartment (e.g.,
adding more shielding or repositioning the device within the vehicle);
Ensure that the licensees name and city/town is prominently displayed as a label on both sides of the
vehicle; and
If an exposure device is transported in an overpack, the procedures should include instructions that
the overpack must be properly marked with an overpack label, the shipping name and UN
identification number, labeled (Radioactive White I or Radioactive Yellow II), and marked when
required with a statement that indicates the inner package complies with prescribed specifications.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 48
Because the licensee may have authorization to possess and use several sealed source/device combinations that
are registered by the NRC or another Agreement State and meet the safety performance requirements of
902 KAR 100:100, the applicant must, before using a new sealed source/device combination, develop written
inspection and maintenance procedures for it and for the corresponding Type B transport package. In addition,
the applicant must provide adequate training for radiographic personnel before using a new sealed source/device
combination.
Response from Applicant
The applicant shall include procedures for transporting sealed sources containing radioactive material, exposure
devices, and source changers in the operating and emergency procedures.
OR
The applicant shall provide a statement to the effect that Devices are not transported beyond the confines of the
applicant’s facilities.
Note: ‘A Review of Department of Transportation Regulations for Transportation of Radioactive Materials
(2008 revision)’ can be obtained at the DOT's Office of Hazardous Material Initiatives and Training at
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/RAM_Regulations_Review_12-2008.pdf .
Before the 1997 revision of 10 CFR Part 34, a licensee who intended to transport a radiographic Type B
package was required to submit a quality assurance program to NRC for approval, separate from the license
approval. The 1997 revision to 10 CFR Part 34 requires written procedures for inspection and maintenance of
radiographic Type B packages (10 CFR 34.31(b)). In conjunction with the revision to 10 CFR Part 34, the
NRC also amended 10 CFR 71.101(g) to specifically state that if the applicant's written procedures for
inspection and maintenance of radiographic Type B packages are approved, then the applicant also meets NRC
quality assurance requirements in 10 CFR Part 71 and does not have to submit or maintain a separate quality
assurance program to transport a Type B package. The application's inspection and maintenance procedures for
radiographic equipment, which are also used for Type B packages, should ensure that these packages are
shipped and maintained in accordance with their COC.
Item 12.7.7: Daily Inspection and Maintenance of Radiography Equipment
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: The licensee shall perform visual and operability checks before using radiography equipment on each
day it is used.
Discussion: Visual and operability checks must be performed on radiographic exposure devices, survey meters,
associated equipment, and transport and storage containers before use each day the equipment is used. These
checks are intended to ensure that the equipment is in good working condition, that the sources are adequately
shielded, and that required labeling is present. Licensees must check survey instrument operability using check
sources or other appropriate means.
Inspection records shall contain information about equipment problems found in daily checks and quarterly [not
to exceed three (3) months] maintenance inspections. Records shall include the date of check or inspection,
name of inspector, equipment involved, any problems found, and what repair and/or maintenance, if any, was
done.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 49
Instructions to personnel using radiographic equipment must clearly state that inspections are to be made before
the equipment is used each day. While not a requirement, good practice would be that if the equipment is used
on more than one shift in the day, the equipment should be inspected before the start of each shift.
The procedures should specify the items that are to be checked and the steps that are to be taken if any defects
are found. If problems are found, the equipment must be removed from service until it is repaired. A list of
items that should be checked in the daily inspection of radiography equipment can be obtained by contacting the
equipment manufacturers.
Permanent radiographic installation visible and audible alarms must be checked for operability daily before use,
and faulty radiographic equipment must be labeled and repaired within seven (7) days, with compensatory
measures taken in the interim. Compensatory measures taken include:
Immediately label faulty equipment as defective;
The radiographer must be accompanied by at least one other radiographer or radiographer’s
assistant;
Continuous surveillance requirements are implemented until repairs are completed;
Alarming ratemeters shall be worn and checked for alarm function at the beginning of each shift; and
Records must be maintained of faulty equipment.
Appendix O provides example instructions for daily inspection of radiographic devices and equipment.
Response from Applicant:
The applicant shall include procedures for daily inspection and maintenance of radiography equipment in the
operating and emergency procedures
Note: Direct reading dosimetry devices must be read and the exposures recorded at the beginning and end of
each shift. Alarming ratemeters shall be checked for alarm function at the beginning of each shift. Records are
to be maintained per 902 KAR 100:100.
Item 12.7.8: Ratemeter Alarms or Off-Scale Dosimeter Readings
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must instruct personnel in:
Appropriate handling and use of sealed radioisotope sources and radiography devices;
Methods and occasions for conducting radiation surveys, controlling access to radiation areas and
locking, securing, and transporting storage containers, radiographic exposure devices, and sealed
radioisotope sources;
The operating and emergency procedures;
Actions to be taken if a dosimeter shows an off-scale reading or an alarm ratemeter alarms (sounds,
etc.) unexpectedly;
Procedures to be followed if a film badge, TLD, OSLD, or similar device is lost or damaged; and
Procedures for notifying the proper persons in the event of an accident.
Discussion: If an individual's self-reading pocket dosimeter is found to be off scale, an individual's electronic
personal dosimeter reads above 2 mSv (200 mrem), or a ratemeter alarms (sounds, etc.) unexpectedly, the RSO
or designee must be notified immediately. If radiation exposure cannot be ruled out by the RSO or designee as
the root cause, the individual’s film badge, TLD, OSLD or similar approved device must be sent for processing
within 24 hours. The affected individual may not resume work with radioactive material until the RSO or
designee has determined the individual's radiation exposure. There are no exemptions to this requirement.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 50
If any of the events described above should occur, personnel should be instructed to do the following at a
minimum:
Stop work immediately, ensure that the source is in the safe storage position in the exposure device,
and vacate the radiation area;
If the ratemeter alarms (sounds, etc.), evaluate pocket dosimeter reading;
Notify the individual specified in the emergency procedures;
Notify the RSO or designee of the problem;
If pocket dosimeter is off scale, do not resume operations until authorized by the RSO or designee;
and
If the exposure cannot be ruled out by the RSO or designee, then the film badge or OSL must be
processed within twenty (24) hours.
Response from Applicant:
The applicant shall include procedures for ratemeter alarms and off scale dosimeters in the operating and
emergency procedures.
Item 12.7.9: Procedure For Identifying And Reporting Defects And Non-Compliance
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensees must notify management if defects are found in radiography equipment.
Discussion: Equipment defects that cause a substantial safety hazard, or equipment failures involving KYDPH-
regulated activities, must be reported to KYDPH. For example, a failure of the coupling between the source
assembly and the control cable must be reported to KYDPH. Radiography personnel should be instructed to
report any malfunction or defect in radiography equipment to management, so that management can take
appropriate action.
Response from the Applicant:
The applicant shall include procedures for notifying management of equipment malfunction or defect in the
operating and emergency procedures.
Note: See NRC IN 91-39 ‘Compliance with 10 CFR part 21, Reporting of Defects and Non-compliance’. This
is available from the NRC website at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-
notices/1991/in91039.html .
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 51
Item 12.7.10: Required Notifications
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: Operating and emergency procedures must ensure that appropriate notifications are made during and
after an emergency.
Discussion: The emergency procedures should clearly identify the names and telephone numbers of the RSO or
other persons who can provide assistance in an emergency or accident. Such persons may also include the
exposure device manufacturer’s and KYDPH’s 24-hour tool free telephone number 1-800-255-2587. The
emergency procedures shall always be available to radiography personnel during radiography and up-to-date.
KYDPH rules also require immediate notification upon the discovery of certain events. Notify KYDPH when
radiographic devices are lost or stolen or if there is indication of overexposure. Refer to the rule stated above or
to Appendix P for additional guidance in the preparation of emergency procedures. Table 9 below provides a
description of events that require notification and/or reports. KYDPH can be notified by calling (502) 564-3700
during normal working hours, Monday through Friday, 8:00 AM to 4:30 PM. After-hours and in the event of an
emergency, KYDPH can be contacted 24/7/365 by calling 1-800-255-2587 which reaches the Duty Officer at
the Commonwealth Emergency Operations Center in Frankfort, KY. Please notify the Duty Officer that this a
radiological event.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 52
Table 9: Required Notifications
EVENT TELEPHONE
NOTIFICATION
WRITTEN
REPORT RULE
Fire, explosion or toxic gas release Immediate 30 days 902 KAR 100:040
Unplanned contamination event 24 hours 30 days 902 KAR 100:040
Equipment is disabled or fails to function as
designed 24 hours 30 days 902 KAR 100:040
Theft or loss of material Immediate 30 days 902 KAR 100:019
Whole body dose greater than 0.25 Sv (25
rems) Immediate 30 days 902 KAR 100:019
Extremity dose greater than 2.5 Sv (250
rems) Immediate 30 days 902 KAR 100:019
Whole body dose greater than 0.05 Sv (5
rems) in 24 hours 24 hours 30 days 902 KAR 100:019
Extremity dose greater than 0.5 Sv (50 rems)
in 24 hours 24 hours 30 days 902 KAR 100:019
Whole body dose greater than 0.05 Sv (5
rems) None 30 days 902 KAR 100:019
Dose to minor greater than 5mSv (500
mrem) None 30 days 902 KAR 100:019
Dose to embryo or fetus of a declared
pregnant woman greater than 5 mSv (500
mrem)
None 30 days 902 KAR 100:019
Dose to individual member of public greater
than 1 mSv (100 mrems) None 30 days 902 KAR 100:019
Any applicable limit in the license or
registration None 30 days 902 KAR 100:019
Leak test of sealed source or guide tube
greater than 185 Bq (0.005 µCi) None 5 days 902 KAR 100:100
Unintentional disconnection of the source
assembly from the control cable None 30 days 902 KAR 100:100
Inability to retract the source assembly to its
fully shielded position and secure it in its
retracted position
None 30 days 902 KAR 100:100
Failure of any component which is critical to
safe operation of the device to properly
perform its intended function
None 30 days 902 KAR 100:100
An indicator on radiation machine fails to
show that radiation is being produced, and
exposure switch fails to terminate production
of radiation when turned to the off position or
a safety interlock fails to terminate x-ray
production
None 30 days 902 KAR 100:100
Use of licensed material at any location not
on license for more than 180 days in a
calendar year
Notify KYDPH
prior to exceeding
180 days
None 902 KAR 100:100
Note: Telephone notifications shall be made to KYDPH at (502) 564-3700 during normal business hours (8 AM
– 4:30 PM) for immediate notifications after normal business hours, the 24 hour emergency telephone number
is (800) 255-2587. Identify the emergency as radiological.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 53
Item 12.7.11: Minimizing Exposure Of Persons In The Event Of An Accident
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: To maintain exposures as low as possible in the event of an emergency.
Discussion: Since it is not possible to specify all possible situations that would constitute an emergency, a
general instruction is acceptable. This general instruction should describe licensee actions to maintain the dose
at a minimal level after an abnormal event is identified. The instruction should include routine emergency
actions such as posting the restricted area, maintaining surveillance of the restricted area, and notifying the
RSO.
General instructions that give a basic idea of how to react when something unexpected happens should include
such direction as immediately move away from the source, while at a safe distance from the source and
maintaining a low exposure, calm down and begin to survey to verify the boundary of the restricted area (2
mR/hr boundary). Remain at this boundary, but maintain visual surveillance of source. Contact RSO or
designee; however, do not leave where you cannot maintain surveillance of source, send someone to the phone
if necessary.
Response from Applicant:
The applicant shall include instructions for minimizing exposure of persons in the event of an accident in the
operating and emergency procedures.
Item 12.7.12: Source Retrieval
Rule: 902 KAR 100:040, 902 KAR 100:100
Criteria: Each licensee who intends to perform source retrieval operations must have appropriate equipment,
training, and procedures.
Discussion: Applicants must develop source retrieval procedures if their own radiographic personnel with
appropriate training and experience will conduct source retrievals. If procedures are submitted, KYDPH will
review and approve applicants to perform source retrieval. If source retrieval procedures are not submitted for
review, then source retrieval activities must be conducted by a licensee whose is specifically authorized for
these activities by KYDPH, NRC or another Agreement State. Proof of successful completion of a device
manufacturer’s source retrieval course is acceptable training for persons authorized by a specific license to
perform source retrieval.
Licensees specifically approved to perform source retrievals will have a specific license condition
authorizing these activities and listing the names of those individuals who are allowed to perform source
retrievals. In addition, these individuals are authorized to perform source retrievals for other licensees.
KYDPH will review the applicant's procedures for source retrieval with respect to keeping exposures ALARA
and controlling exposures to radiation. Since it is not possible to specify all potential exposure situations, a
general procedure is acceptable.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 54
A retrieval procedure should contain the following elements:
Warnings that only specifically authorized individuals, or personnel supervised by such authorized
individuals and working in their physical presence are allowed to perform retrievals;
A clear statement that no source or suspected source containing items such as a stuck source in a
guide tube will be handled directly;
Expedient methods of reducing unintended exposure to staff and the public, such as using lead shot
bags, sandbags, steel plates, remote handling devices, and culverts cut lengthwise;
Additional dosimetry should be used during source retrievals, for example, pocket dosimeters with a
range greater than 2 mSv (200 mrem) or finger badges;
Methods of restricting access to the area, including establishing a restricted area and obtaining
outside help in controlling access;
Appropriate use of survey instruments. The procedure should prohibit using alarming dosimeters or
electronic dosimeters as survey instrument substitutes;
Criteria for requesting outside assistance;
Instructions for reducing the exposure to other personnel and members of the public during recovery
operations;
Notification of the RSO/RSO-designee, and management;
Specific training including practice with special tools, shielding, and additional dosimetry with a
dummy source; and
Notification to KYDPH.
Response from Applicant:
The applicant shall provide a statement to the effect that the applicant will not perform source retrieval and will
use the services of a person specifically licensed by KYDPH, NRC or another Agreement State to perform the
retrievals of our sources.
OR
If the applicant will perform source retrieval; the applicant shall include source retrieval procedures in the
operating and emergency procedures and submit specific training for agency review
Note: Radiography personnel should not attempt to perform operations involving source retrieval or recovery
unless they have actual training in retrieval operations using a dummy source with the appropriate handling
tools, survey instruments, and dosimetry. Source retrieval must be specifically authorized on the license and the
persons conducting those activities specifically named.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 55
Item 12.7.13: Maintenance Of Records
Rule: 902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100
Criteria: The licensee shall meet KYDPH record requirements.
Discussion: Personnel must generate and maintain certain records when performing radiography, including:
Utilization logs showing the following:
Description, including the make, model, and serial number of the device used.
Identification and signature of the radiographer.
Where the device is used and dates of use; dates device is removed and returned to storage.
Records of daily inspection of equipment;
Pocket dosimeter readings. These readings must be made at the beginning and end of a work shift.
Instructions to personnel must specify that the readings be recorded; and
Results of the physical survey to ensure that the sealed source is in the shielded position, when a
radiographic exposure device is placed in a storage area (as defined in 902 KAR 100:010) and if that
survey is the last one performed in the workday.
Operations requiring records include inspections and maintenance at intervals not to exceed three (3) months.
Other examples include instrument calibration and shipment of packages. Radiography personnel should also
be aware of the records that must be maintained at temporary jobsites listed in 902 KAR 100:100 Section 17.
Radiographers performing radiographic duties should be given specific instructions for recordkeeping. These
should not include instructions about records that are the responsibility of management and supervision.
Response from the Applicant:
The applicant shall include procedures which ensure proper maintenance of records in the operating and
emergency procedures.
AND
The applicant shall include the physical address where records can be reviewed by KYDPH Monday through
Friday during normal working hours. The address provided by the applicant shall NOT be a Post Office Box.
Item 12.8: Minimization of Contamination
Rule: 902 KAR 100:040, 902 KAR 100:042
Criteria: Applicants for new licenses must describe how facility design and procedures for operation will
minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual
decommissioning, and minimize, to the extent practicable, the generation of radioactive waste.
Discussion: All applicants for new licenses need to consider the importance of designing and operating their
facilities to minimize the amount of radioactive contamination generated at the site during its operating lifetime
and to minimize the generation of radioactive waste during decontamination. Industrial radiography applicants
usually do not need to address these issues as a separate item since they are included in responses to other items
of the application.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 56
Sealed source and devices that are approved by the NRC or another Agreement State and located and used
according to their respective SSDR Certificates usually pose little risk of contamination. Leak tests performed
as specified in 902 KAR 100:100 should identify defective sources. Leaking sources must be withdrawn from
use and decontaminated, repaired, or disposed of according to 902 KAR 100, ‘Kentucky Radiation Protection
Regulations’. These steps minimize the spread of contamination and reduce radioactive waste associated with
decontamination efforts. Other efforts to minimize radioactive waste do not apply to programs using only
sealed sources and devices that have not leaked.
Note: The applicant does not need to provide a response to this item. KYDPH will consider that the above
Criteria have been met if the applicant's responses meet the criteria for the following items: ‘Sealed Sources and
Devices’, ‘Facilities and Equipment’, ‘Leak Tests’, ‘Operating and Emergency Procedures’, and ‘Waste
Management’.
Item 14: Waste Management
Rule: 902 KAR 100:021, 902 KAR 100:040, 902 KAR 100:100
Criteria: Licensed materials must be disposed of in accordance with KYDPH requirements by transfer to an
authorized recipient. Appropriate records must be maintained.
Discussion: Licensees who dispose of radiography sealed sources, or dispose of radiography devices
containing depleted uranium, must transfer them to an authorized recipient. Recipients authorized to accept
radioactive material are the original manufacturer of the device, or a commercial firm licensed by KYDPH, the
NRC or another Agreement State.
Before transferring radioactive material, a licensee must use one of the methods described in 902 KAR 100:040
to verify that the recipient is properly authorized to receive it. In addition, all packages containing radioactive
sources must be prepared and shipped in accordance with KYDPH/DOT requirements. Records of the transfer
must be maintained as required by 902 KAR 100:040.
Response from Applicant:
The applicant shall provide a statement to the effect that the applicant will return the radiography sealed
source(s) to the manufacturer for disposal or transfer the radiography sealed source(s) to a specific licensee
authorized by KYDPH, the NRC or another Agreement State to receive radioactive material.
Note: Because of the difficulties and costs associated with disposal of sealed sources containing radioactive
material and devices containing depleted uranium, applicants should preplan the disposal. Applicants may want
to consider contractual arrangements with the sealed source and device supplier as part of a purchase
agreement.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 57
License Fees
Rule: 902 KAR 100:012, 902 KAR 100:040
Criteria: The applicant must submit the appropriate application fee in the form of a check or money order made
payable to the Kentucky State Treasurer.
Response from Applicant:
The applicant shall submit the applicable application fee as stated in 902 KAR 100:012. Fee Schedule
(http://www.lrc.state.ky.us/kar/902/100/012.htm). See also the “Kentucky Radioactive Materials License Fee
Schedule” at the following website http://www.chfs.ky.gov/dph/radioactive.htm.
Note: An application submitted without the applicable fee will not be processed until such time as the fee is
paid in full
Item 15: Certification
Criteria:
Individuals acting in a private capacity are required to sign and date KYDPH Form RPS-7, ‘Application
for a Radioactive Material License’ (Appendix A).
Senior management representatives of a corporation or legal entity must sign and date KYDPH Form
RPS-7, ‘Application for a Radioactive Material License’ (Appendix A). Senior management personnel
include the President, Chief Executive Officer, Chief Operating Officer, etc. KYDPH also uses the
required corporate filings made with the Kentucky Secretary of State’s office to determine who is a
member of senior management (http://sos.ky.gov/bus/business-filings/Pages/default.aspx). All entities
doing business in Kentucky, including corporations, limited liability companies, limited partnerships
and business trusts, must file an annual report with the KY SOS by June 30 of each year. Failure to file
the annual report by June 30 will result in the entity being listed in bad standing with this office and
could lead to administrative dissolution or revocation of authority to do business in Kentucky.
Representatives signing an application must be authorized to make binding commitments and sign
official documents on behalf of the applicant. As discussed in the section titled ‘Management Responsibility’,
signing the application acknowledges management's commitment and responsibilities for the radiation
protection program. KYDPH will return all unsigned applications for proper signature.
Response from Applicant:
15. Certification. The applicant understands that all statements and representations made in the application are binding upon the applicant.
The applicant and any official executing this certification on behalf of the applicant, named in Item 1, certify that this application is prepared in conformity with Kentucky Cabinet for Health and Family Services Administrative Regulations 902 KAR 100, and that all information contained herein, is true and correct to the best of their knowledge and belief.
Signature of Certifying Management Official Type/Printed Name Title Date
Note:
It is a violation of 902 KAR 100:170 to make a willful false statement or representation on applications
or correspondence.
When the application references commitments, those items become part of the licensing conditions and
regulatory requirements.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 58
Appendix A
KYDPH Form RPS-7
‘Application for a Radioactive Material License’
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 59
Application for a Kentucky Radioactive Materials License
Radiation Health Branch, Department for Public Health
Cabinet for Health and Family Services
Completed applications must be filed with Radiation Health Branch, Cabinet for Health and Family Services, 275 East Main Street, Mailstop HS1C-A, Frankfort, KY 40621, Tel: 502-564-3700, Fax: 502-564-1492 Application is for one of the following:
New License(1)
Check.______ Amendment in Entirety
(1) of License
No._________________________ Amendment to
(2, 3) License
No._______________________ Renewal of
(2, 3) License
No.______________________
(1) All sections must be completed (2) Complete all applicable sections & section 15 (3) Amendments & renewals cannot be combined
1. Applicant’s Name and Mailing Address
2. Street address(es) where radioactive material will be Used (no P.O. Boxes)
3. Telephone Number
4. Person to be contacted and listed as contact person
5. Individual(s) and Title(s) who will use or directly supervise use of radioactive material
6. Radiation Safety Officer (one person)
Training and experience required for each user named in Item 5 and for the Radiation Safety Officer in Item 6. For the RSO, duties and responsibilities of the RSO and updated organizational chart are required and if necessary, a signature authorization form.
7. Licensed Material
Element & Mass
Number
A
Chemical and/or
Physical Form
B
Manufacturer Name & Model Number (if sealed
source)
C
Maximum activity (millicuries) per sealed
source OR maximum activity possessed at any one time
D
Maximum number of sealed source/device
combinations possessed at any one
time E
Describe use of radioactive material (Should be keyed to material in Subitem A above. For specific make & model of sealed source/device combinations in Subitem E above, state maximum number possessed at any one time)
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 60
8. Radiation Detection Instruments
Manufacturer
Model
Number Available
Radiation Detected (alpha, beta, gamma, neutron)
Sensitivity
Range
9. a) Calibrated by Service Company (Name, Address, and Frequency)
b) Calibrated by Applicant (Attach procedures describing method and standards used)
10. Personal Monitoring Devices
Type Supplier Exchange Frequency
(1) Film Badge (2) TLD (3) OSLD (4) Other (specify)
Monthly Bi-monthly Quarterly Other (specify)
11. Facilities and Equipment. Describe the facilities, remote handling equipment, shielding, fume hoods, etc. Attach a sketch of the facility indicating the location of any radioactive materials (i.e. fixed gauges, storage areas, etc.).
12. Radiation Protection Program. Describe the radiation protection program as appropriate for the material to be used including the duties and responsibilities of the Radiation Safety Officer, control measures, bioassay procedures, day-to- day general safety instruction to be followed, etc. If sealed sources are to be possessed, describe leak test procedures or if kit is used specify the manufacturer, model number of kit and person performing test. If radiation detection instruments are to be calibrated in-house or leak test swipes analyzed, submit detailed procedures and methods.
13. Training and Experience of Users. Submit the formal training of each individual named in Item 5 and 6 indicating the name of persons or institutions providing the training, duration of training, and when training received in the areas of: A) Principles and practices of radiation protection. B) Radioactivity measurement standardization and monitoring techniques and instruments. C) Mathematics and calculations basic to the use and measurement of radioactivity. D) Biological effects of radiation.
14. Waste Disposal. Describe the methods which will be used for disposing of radioactive waste.
15. Certification. The applicant understands that all statements and representations made in the application are binding upon the applicant.
The applicant and any official executing this certification on behalf of the applicant, named in Item 1, certify that this application is prepared in conformity with Kentucky Cabinet for Health and Family Services Administrative Regulations 902 KAR 100, and that all information contained herein, is true and correct to the best of their knowledge and belief.
Signature of Certifying Management Official Type/Printed Name Title Date
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 61
Appendix B
KYDPH Form RPS-10
‘Disposition of Radioactive Material’
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 62
RPS-10 - DISPOSITION OF RADIOACTIVE MATERIAL
Radiation Health Branch Department for Public Health
Cabinet for Health and Family Services 275 East Main Street
Mailstop HS1C-A Frankfort, KY 40621
1. Licensee Name
2. Address
3. Radioactive Material License Number
4. Expiration Date
5. Radioactive Material Disposition for (check one only) Transfer Termination (see 8 below).
6. Check one of the following and provide any requested information
A. No radioactive material has been procured and/or possessed by the licensee under this license.
B. All licensed activities have ceased and all radioactive material procured and/or possessed by the licensee has been transferred to the following licensee/supplier:
Name
Address
License Number
Date Transferred
C. All licensed activities have ceased and all radioactive material has been
disposed of in the following manner. (Describe specific disposal procedures. Use reverse side of form if necessary)
7. If unsealed sources or a leaking sealed source of radioactive material had been used,
submit a copy of a radiation survey conducted to determine whether any contamination remains at location(s) authorized by license.
Survey not required. (Explain)
Survey report attached.
8. If the license is to be terminated a Low Level Radioactive Waste Form Must Be Submitted. This form is on the Radiation Health Branch Website at http://chfs.ky.gov/dph/radiation.htm 9. Form must be signed and dated by person authorized to act on behalf of licensee.
I hereby certify that the information provided is true and correct to the best of my knowledge and belief. ____________________________________________________ __________________
Signature Date ____________________________________________________ __________________
Typed/Printed Name Title
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 63
Appendix C
Sample ‘Delegation of Authority to Radiation
Safety Officer’ Letter
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 64
MODEL DELEGATION OF AUTHORITY TO THE RSO
(to be printed on company letter head)
Date: (required) Memo To: (write in name & title of person being granted RSO authority) From: (write in name & title of Senior Management official granting RSO authority) .
(e.g. President, Chief Executive Officer) Subject: Delegation of Authority to the Radiation Safety Officer You have been appointed Radiation Safety Officer for license number ____________. You are responsible for
ensuring the safe use of radiation. You are responsible for managing the radiation safety program; identifying
radiation safety problems; initiating, recommending, or providing corrective actions; verifying implementation of
corrective actions; stopping unsafe activities; and ensuring compliance with the regulations 902 KAR 100 and
compliance with the terms and conditions of the license and commitments contained therein. You are hereby
delegated the authority necessary to meet those responsibilities, including prohibiting the use of radioactive
material by employees who do not meet the necessary requirements and shutting down operations where
justified by radiation safety. You are required to notify management of situations where staff are not
cooperating and not addressing radiation safety issues. In addition, you are free to raise issues with the
Radiation Health Branch, Frankfort, KY at any time.
Signature and Title of Management
I, hereby I accept the above delegated authority. (print name)
Signature of the Radiation Safety Officer
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 65
Appendix D
Sample ‘Signature Authorization’ Letter
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 66
MODEL SIGNATURE AUTHORIZATION FORM
(To be submitted on company letter head) Date: (required) Memo To: , Title of person being granted signature authority (e.g., RSO, EH&S Supervisor, etc.) From: , Title of Senior Management granting that authority
(e.g. Chief Executive Officer, President, etc.) Subject: Delegation of Signature Authority for License Number
I hereby delegate authority to you for making commitments and signing amendment requests to the
Kentucky radioactive materials license for (write in name and address of license ) on behalf of
senior management. As a member of management, I recognize the radioactive materials license is a
legal document that includes the application and all approved amendments. Furthermore, only
management can obligate the institution and management is held accountable for the commitments in
the license. In addition, I acknowledge that only a member of management has authority to provide
necessary resources to achieve regulatory compliance. Necessary resources include finance,
personnel, and physical plant.
Signature and Title of Management I, hereby I accept the above delegated authority. (print name) Signature of the authorized individual
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 67
Appendix E
Information Needed for Transfer of
Control of a License
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 68
Information Needed for Transfer of Control of a License
Licensees must provide full information and obtain KYDPH’s prior written consent before transferring
control of the license; some licensees refer to this as ‘transferring the license’. Provide the following
information concerning changes of control by the applicant (transferor and/or transferee, as appropriate). If any
items are not applicable, so state.
Control: Control of a license is in the hands of the person or persons who are empowered to decide when and
how that license will be used. That control is to be found in the person or persons who, because of ownership or
authority explicitly delegated by the owners, possess the power to determine corporate policy and thus the
direction of the activities under the license.
Transferee: A transferee is an entity that proposes to purchase or otherwise gain control of a
KYDPH-licensed operation.
Transferor: A transferor is a KYDPH licensee selling or otherwise giving up control of a licensed operation.
1. The new name of the licensed organization. If there is no change, the licensee should so state.
2. The new licensee contact and telephone number(s) to facilitate communications.
3. Any changes in personnel having control over licensed activities (e.g., officers of a corporation) and
any changes in personnel named in the license such as radiation safety officer, authorized users, or any
other persons identified in previous license applications as responsible for radiation safety or use of
licensed material. The licensee should include information concerning the qualifications, training, and
responsibilities of new individuals.
4. An indication of whether the transferor will remain in non-licensed business without the license.
5. A complete, clear description of the transaction, including any transfer of stocks or assets, mergers,
etc., so that legal counsel is able, when necessary, to differentiate between name changes and
transferring control.
6. A complete description of any planned changes in organization, location, facility, equipment, or
procedures (i.e., changes in operating or emergency procedures).
7. A detailed description of any changes in the use, possession, location, or storage of the licensed
materials.
8. Any changes in organization, location, facilities, equipment, procedures, or personnel that would
require a license amendment even without transferring control.
9. An indication of whether all surveillance items and records (e.g., calibrations, leak tests, surveys,
inventories, and accountability requirements) will be current at the time of transfer. Provide a
description of the status of all surveillance requirements and records.
10. Confirmation that all records concerning the safe and effective decommissioning of the facility,
pursuant to 902 KAR 100:042. Decommissioning and financial surety.
(http://www.lrc.ky.gov/kar/902/100/042.htm ); public dose; and waste disposal by release to sewers,
incineration, radioactive material spills, and on-site burials, have been transferred to the new licensee,
if licensed activities will continue at the same location, or to the KYDPH for license terminations.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 69
11. A description of the status of the facility. Specifically, the presence or absence of contamination
should be documented. If contamination is present, will decontamination occur before transfer? If not,
does the successor company agree to assume full liability for the decontamination of the facility or
site?
12. A description of any decontamination plans, including financial assurance arrangements of the
transferee, as specified in 902 KAR 100:042. Decommissioning and financial surety.
(http://www.lrc.ky.gov/kar/902/100/042.htm ). Include information about how the transferee and
transferor propose to divide the transferor's assets, and responsibility for any cleanup needed at the
time of transfer.
References: The information above is derived from Information Notice 89-25, Revision 1, “Unauthorized
Transfer of Ownership or Control of Licensed Activities,” which is available at the NRC’s webpage at
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1989/in89025.html .
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 70
RPS-12 – TRANSFER OF CONTROL OF RADIOACTIVE MATERIAL LICENSE
Radiation Health Branch Department for Public Health
Cabinet for Health and Family Services 275 East Main Street
Mailstop HS1CA Frankfort, KY 40621
1. Licensee Requesting Permission from KYDPH to Transfer Control of Its RAM License:
Current Facility Name:
Address:
License Number Expiration Date:
(The Radiation Health Branch reviews requests for transfer of license control on a case-by-case basis and may require application
for a new license and termination of the existing license. Transfer of license control before notification, licenses more than five years
old and not Amended in Entirety within five years are subject to increased scrutiny in accordance with 902 KAR 100:040.
http://www.lrc.ky.gov/kar/902/100/040.htm)
2. Entity Requesting Permission from KYDPH to Take Control of Above RAM License
Name:
Address:
Registered with the Kentucky Secretary of State’s Office: Yes No
If yes, under what name:
If no, please explain why not:
(All corporations (profit, non-profit & professional service), limited liability companies (profit, non-profit & professional
service), limited partnerships (filed under 2006 Act), limited liability limited partnerships and business trusts are required by
law to register with the Kentucky Secretary of State and to file an annual report by June 30 of each year
http://www.sos.ky.gov/business/filings/ )
3. All “Information Needed for Transfer of Control Application” as described on the following page has been submitted for
review by KYDPH and is complete and accurate.
Yes No If not, state why:
4. Form must be signed and dated by person authorized to act on behalf of the licensee requesting permission from KYDPH to
transfer control of its existing RAM license.
Signature Typed/Printed Name Date
FOR RADIATION HEALTH BRANCH USE ONLY
Reviewer
Review Date Date License Issued or AE
Meets Requirements for Transfer of Control
Yes No
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 71
Appendix F
NRC Regulatory Issue Summary 2005-10
‘Performance-Based Approach for Associated
Equipment in 10 CFR 34.20’
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 72
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/2005/ri200510.pdf
ADDRESSEES
All industrial radiography licensees and manufacturers and distributors of industrial radiography
equipment.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to explain the performance-based approach NRC has decided to take regarding the requirements in
10 CFR 34.20, “Performance requirements for industrial radiography equipment”, which addresses the
regulation of associated equipment used in an industrial radiography system. This RIS supersedes and replaces
Information Notice 96-20, “Demonstration of Associated Equipment Compliance with 10 CFR 34.20”. No
specific action or written response is required.
BACKGROUND
In the Federal Register notice (68 FR 41757, July 15, 2003), NRC announced its denial of the petitioner's
request for rulemaking to remove from 10 CFR 34.20 the term “associated equipment". The notice also
explained that NRC's practice of registering associated equipment under 10 CFR 32.210, "Registration of
product information", which was previously described in Information Notice 96-20, had been discontinued.
This RIS supersedes and replaces Information Notice 96-20.
SUMMARY OF ISSUE
To maintain safety, each licensee must take special care to ensure that all associated equipment (including
modified or customized associated equipment) meets the minimum performance criteria required in 10 CFR
34.20. A licensee that modifies associated equipment is required to demonstrate by actual testing or an
alternative analysis that the performance of the radiographic system and individual items of associated
equipment meet the criteria in 10 CFR 34.20. The results of actual testing or analysis must demonstrate that the
replacement component will not compromise the design safety features of the industrial radiography system.
Compliance with the performance criteria prevents a licensee from using substandard associated equipment.
PERFORMANCE REQUIREMENTS FOR ASSOCIATED EQUIPMENT
The performance requirements for associated equipment are set forth in the paragraphs of
10 CFR 34.20, described below:
• paragraph (a)(1), incorporates by reference the American National Standards Institute
(ANSI) N432–1980, “Radiological Safety for the Design and Construction of Apparatus for Gamma
Radiography”, (ANSI N432) which specifies the design and method of qualifying (testing) industrial
radiography equipment, including equipment that NRC has defined as “associated equipment”;
• paragraph (a)(2), provides for an engineering analysis as an alternative to actual testing, to demonstrate
the performance of individual radiography equipment components;
• paragraph (b)(3), allows associated equipment to be modified unless the replacement component would
compromise the design safety features of the industrial radiography system;
• paragraph (c)(5) and (8), respectively address crushing and kinking tests for a guide tube and the
standard test for tensile strength of an exposure head;
• paragraph (e), allows a licensee or vendor to apply a realistic torque to the drive mechanism during the
life cycle test.
The regulations require a licensee to use industrial radiography equipment that has been manufactured and
tested to meet radiation safety performance criteria under 10 CFR 34.20.
The life cycle test in ANSI N432 is an evaluation of the endurance of a source or device. To test the life cycle
of an industrial radiography source or exposure device, all components of the industrial radiography system
(including the associated equipment) must be assembled and operated for the duration of the test. This
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 73
requirement, NRC determined, is sufficient to maintain safety and a separate regulatory approval for associated
equipment is not needed as long as the associated equipment meets the minimum criteria in 10 CFR 34.20.
Attachment 1 to this RIS contains additional information about definitions and applicable requirements,
certificates of registration for a sealed source or device, custom-built items of associated equipment, acceptable
methods to demonstrate compliance, inspection and licensing guidance, and inspection and maintenance
procedures. Attachment 2 indicates the availability of reference documents that are cited in this RIS and
Attachment 1.
ENFORCEMENT POLICY
The NRC Enforcement Policy, Supplement VI, provides examples of violations in each of the four severity
levels as guidance in determining the appropriate severity level for violations in the area of fuel cycle and
materials operations, including industrial radiographic operations. An example of an activity that would
normally result in the NRC issuing a Severity Level III Notice of Violation is possession or use of unauthorized
equipment or materials in the conduct of licensee activities that degrades safety. Based on this example,
enforcement action would be considered for a licensee that used associated equipment that had not been tested
or analyzed to meet the performance requirements or that used modified associated equipment that
compromised the design safety features of an industrial radiography system and threatened or did not protect the
health and safety of workers or members of the public.
AGREEMENT STATE COMPATIBILITY
NRC has determined that the information provided in this RIS does not change the level of compatibility of the
Agreement State regulations to the existing NRC requirements. Use of the information in this RIS continues to
provide Agreement States with the flexibility to revise their policy and guidance to meet unique situations and
local conditions and to ensure an orderly, uniform implementation of the performance-based approach for
associated equipment.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment on this RIS was not published in the Federal Register because it is
informational, and does not represent a departure from current regulatory requirements.
SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT
NRC has determined that this action is not subject to the Small Business Regulatory Enforcement Fairness Act
of 1996.
PAPERWORK REDUCTION ACT STATEMENT
This RIS requires no specific action or written response. If you have any questions about this summary, please
contact one of the individuals listed below or the appropriate regional office.
/RA/ Thomas Essig for
Patricia K. Holahan, Acting Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contacts: J. Bruce Carrico, NMSS Thomas Young, NMSS
301-415-7826 301-415-5795
E-mail: [email protected] E-mail: [email protected]
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic
Reading Room/Document Collections.
Attachments: 1. Additional Information and Applicable Requirements Regarding Associated Equipment
2. Availability of Reference Documents
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 74
Attachment 1
ADDITIONAL INFORMATION AND APPLICABLE REQUIREMENTS REGARDING
ASSOCIATED EQUIPMENT
Definitions
10 CFR 34.3, “Definitions”, defines associated equipment as equipment that is used in conjunction with a
radiographic exposure device to make radiographic exposures that drives, guides, or comes in contact with the
source [e.g., guide tube, control tube, control (drive) cable, removable source stop, ‘J’ tube, and collimator
when it is used as an exposure head]. 10 CFR 34.3 defines the following items of associated equipment:
collimator, control (drive) cable, control (drive) mechanism, control tube, exposure head (source stop), and
guide tube. 10 CFR 34.3 defines the following radiographic equipment and related terms: radiographic
exposure device, s-tube, sealed source, source assembly, source changer, and storage container.
Licensees should be aware of the specific meaning of the terms indicated above. The requirements applicable
to items of equipment depend on how the equipment is defined in 10 CFR 34.3. It is important to distinguish
between items of equipment that are considered to be associated equipment and items of equipment that are not.
In some cases, there may be no regulatory requirements that apply to an item of equipment; in other cases, an
item of equipment may be a component of a source or device that is required to be specifically authorized for
use. Following are two examples that illustrate important distinctions which determine regulatory requirements
for an item of equipment.
The first example distinguishes certain types of collimators that are not associated equipment and are not
required to meet the performance criteria in ANSI N432. Various types of collimators are used as radiation
safety devices for industrial radiographic operations. In many cases, the exposure head at the end of the guide
tube is inserted into a collimator. This type of collimator is not an item of associated equipment because the
source does not come in contact with the collimator. This type of collimator is not subject to the performance
requirements in 10 CFR 34.20 or the evaluation process in 10 CFR 32.210. However, if a collimator does
come in contact with the source because it also acts as a source stop (exposure head), then it falls within the
scope of the definition of associated equipment that is subject to the performance requirements in 10 CFR
34.20.
The second example distinguishes the connector that is located between the sealed source and the control
(drive) cable. 10 CFR 34.3 defines the source assembly to include the connector, stating, “Source assembly
means an assembly that consists of the sealed source and a connector that attaches the source to the control
cable”. The connector is a component of the source assembly and is, therefore, not an item of associated
equipment. The source assembly is subject to the requirements in 10 CFR 30.32, “Application for a specific
license”. 10 CFR 30.32(g) indicates that an application for a specific license to use byproduct material in the
form of a sealed source or in a device that contains a sealed source must either identify the sealed source or the
device as registered under 10 CFR 32.210 or with an Agreement State or must include the information
identified in 10 CFR 32.210(c). The manufacturing processes used to attach the connector to the source cable
and to the control (drive) cable are also subject to evaluation by NRC or an Agreement State under these
requirements.
Portable industrial radiographic systems typically include a two-piece connector (swivel coupling design) to
attach the source assembly to the control (drive) cable in order to operate the system. The performance-based
requirement in 10 CFR 34.20(c)(1) indicates that the coupling must be designed such that it cannot be
unintentionally disconnected under normal and reasonably foreseeable abnormal conditions. The Statements of
Consideration at 55 FR 843 (January 10, 1990) include a response to comments received for 10 CFR
34.20(c)(1). The response indicates, “NRC’s source and device registration process will ensure compliance with
this performance requirement by requiring NRC approval before the newly designed connectors could be used”.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 75
The sealed source or device evaluation process ensures compliance with the performance criteria in the rule.
Both pieces of the two-piece connector are subject to evaluation under 10 CFR 30.32(g) or 32.210(c).
Sealed Source and Device (SS&D) Certificate of Registration
NRC determined that the previous practice of registering associated equipment under 10 CFR
32.210 was not only not required, but was a regulatory practice that imposed an unnecessary burden on
licensees and for NRC and the Agreement States which are authorized to evaluate SS&Ds. Therefore, this
practice has been discontinued. NRC does not intend to independently revise current SS&D certificates of
registration only to remove references to associated equipment. If it becomes necessary to amend a current
SS&D certificate of registration, the applicant may remove or update the information about associated
equipment in the application.
As a matter of convenience, an SS&D applicant under 10 CFR 32.210 may describe the associated equipment
that was used in the life cycle test for the radiographic source or device that is being registered; however, there
is no requirement to do so. If an applicant wants the associated equipment to be included on the certificate of
registration, the application which describes associated equipment must include sufficient information to
demonstrate that the performance criteria were met for associated equipment under 10 CFR 34.20. If a
certificate of registration does not identify the associated equipment that was used in the system along with the
source or device, then each end-user (licensee) must demonstrate that the items of associated equipment which
the licensee uses in the system meet the performance criteria under 10 CFR 34.20 and do not compromise the
design safety features of the system.
NUREG-1556, Volume 3, Revision 1, “Consolidated Guidance About Materials Licenses–Applications for
Sealed Source and Device Evaluation and Registration”, (Final Report, April 2004), Section 4.6, “Radiography
Equipment”, indicates that there is no requirement to identify associated equipment for an SS&D certificate of
registration. Note–In Section 15, “Glossary”, the definition of "associated equipment" was intended to be
removed and should be disregarded because it has been superseded by Section 4.6.
Custom-Built or Unique Items of Associated Equipment
Associated equipment specifically designed and constructed to the order of a single licensee must comply with
the performance criteria in 10 CFR 34.20. There is no requirement to register custom-built or unique items of
associated equipment. However, when modified or custom-built associated equipment introduces components
or fabrication methods that differ from those that were used in the endurance test for a source assembly or
exposure device that was previously registered, the licensee must demonstrate compliance with the
requirements in 10 CFR 34.20 before the equipment can be used for industrial radiographic operations. For
example, licensees must obtain information demonstrating that modified guide tubes and exposure heads will
withstand tests that demonstrate the equipment will maintain its integrity in normal use and likely accident
conditions.
Acceptable Methods to Demonstrate that Associated Equipment Complies with 10 CFR 34.20
The performance-based approach that NRC has decided to take for associated equipment recognizes that a
licensee has latitude to use modified components, unless the design of any replacement component would
compromise the design safety features of the system. Further guidance about testing or an alternative analysis to
testing is described in NUREG-1556, Volume 3, Revision 1, Section 10.5, “Prototype Testing”. The NUREG
addresses appropriate methods a licensee may use to demonstrate the ability of a modified industrial
radiography system to maintain its integrity when subjected to conditions of normal use and likely accident
conditions.
For example, information about an equivalent system that was previously registered may be used to demonstrate
safety and integrity of the modified system, if the design of the modified system and its intended normal and
likely accident conditions of use are identical or similar to the previously registered system. In some cases, an
engineering analysis or operational history with supporting documentation may be sufficient for a licensee to
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 76
justify the use of a modified system without repeating, e.g., an endurance test. However, when an appropriate
comparison to the previously registered system is not possible because a licensee is unable to obtain appropriate
information about previous prototype testing, engineering analysis, or operational history for the previously
registered system or item of associated equipment, then the licensee must complete actual testing of the
modified system and the individual items of associated equipment to demonstrate compliance with 10 CFR
34.20.
NRC contracted a testing laboratory to complete actual testing of three industrial radiography systems from
three manufacturers. The contractor developed procedures to test the systems and individual items of associated
equipment to meet the performance criteria in 10 CFR 34.20. In a similar manner, a licensee could contract a
testing laboratory or manufacturer of industrial radiography equipment to test or analyze a modified system or
component that will be used in a system that was previously licensed or registered.
If a licensee needs to modify associated equipment, the licensee should adopt and implement a suitable
engineering procedure or plan to ensure that a modified component will not compromise the design safety
features of the industrial radiographic system. Implementation of such a procedure or plan should demonstrate
that modifications to the equipment: (1) will not create material incompatibility that may degrade a sealed
source or device over the expected useful life time; (2) will not diminish the performance of the system in
expected use environments and in likely accident conditions over the expected life time of the various system
components; (3) will not allow a source to inadvertently exit the system; and (4) will not initiate or propagate
equipment failures resulting in a “source disconnect.” An endurance test for a modified system should indicate
that the modified component does not interfere with the performance of the components of the system that were
previously registered.
Examples of the performance-based approach that NRC has decided to use for 10 CFR 34.20 are included in
the following paragraphs to illustrate situations when a licensee must complete testing or analysis of associated
equipment to demonstrate that the associated equipment meets the performance criteria in 10 CFR 34.20 and
does not compromise the design safety features of the system.
It is acceptable for a licensee to assume that no further testing is needed for associated equipment which is listed
along with the source or device as an entire system on the certificate of registration because the associated
equipment has already been verified to meet the performance criteria in 10 CFR 34.20 when the associated
equipment is used with the source or device. However, a licensee that substitutes associated equipment into an
industrial radiography system that was registered as an entire system which specified the associated equipment
must demonstrate that the reconfigured system meets the performance criteria under 10 CFR 34.20.
It is acceptable for a licensee to assume that associated equipment that is used as the manufacturer intended as
described in the SS&D certificate of registration meets the performance criteria under 10 CFR 34.20. The
SS&D certificate of registration indicates the principal use, normal conditions of use, and the limitations on use
for the source or device. However, a licensee that uses associated equipment in a manner that was not intended
by the manufacturer as described in the SS&D certificate of registration for the source or device must describe
the conditions of use for the equipment and obtain information about performance of the equipment under these
conditions of use to demonstrate compliance with 10 CFR 34.20. Conditions of use include, for example,
extremely hot or cold operating temperature, excessive vibration or shock, high concentrations of corrosive
materials, and underwater usage.
Inspection and Licensing Guidance
NRC is revising inspection and licensing guidance to incorporate the explanation provided by this RIS.
Inspection Procedure 87121, “Industrial Radiography Programs”, directs an inspector to follow a performance-
based approach to examine available associated equipment, observe work in progress that involves use of
associated equipment, and interview workers about the inspection and maintenance procedures and the worker’s
awareness that associated equipment must comply with the performance criteria in 10 CFR 34.20.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 77
If the associated equipment appears to be modified or defective, the inspector should verify whether or not the
licensee had developed and implemented a testing program to demonstrate that modified components meet the
performance criteria in 10 CFR 34.20. The inspector should alert the inspection supervisor who may extend the
inspection and request an SS&D reviewer to evaluate the licensee’s modification of the equipment. The
expectation is that the design safety features of the industrial radiography system were not compromised by a
replacement component of associated equipment that was modified by the licensee. Before using the modified
system, the licensee is required to demonstrate that the replacement component meets the performance criteria
in 10 CFR 34.20.
NUREG-1556, Volume 2, “Consolidated Guidance about Materials Licensees–Program-Specific Guidance
about Industrial Radiography Licenses” (Final Report, August 1998) is being amended to remove statements
that indicate associated equipment must be specifically approved or registered by NRC or an Agreement State.
Instead, the guidance will state that vendors or distributors of industrial radiography equipment may voluntarily
include the items of associated equipment that were used in the system with their SS&Ds that are registered
under 10 CFR 32.210. To include associated equipment in the certificate of registration, the vendor’s
application must include information that demonstrates the associated equipment meets the minimum criteria in
10 CFR 34.20. Also, copies of this RIS will be inserted into Appendix F to replace Information Notice 96-20.
Inspection and Maintenance Procedures
NRC completed a generic assessment and special team inspection which was published in NUREG-1631,
“Source Disconnects Resulting from Radiography Drive Cable Failures” (June 1998). The inspection team
observed that, in general, radiography exposure devices appeared to be in good working order, showing no
evidence of damage, abuse, or lack of maintenance. By contrast, the associated equipment (i.e., control
mechanisms, including drive cables) often appeared to be damaged, in disrepair, and lacking maintenance.
NUREG-1631 emphasized the importance of a licensee's understanding and commitment to the operating and
use conditions specified by a vendor (manufacturer or distributor) of an industrial radiography system which, if
exceeded, could compromise the safety and reliability of the system. This is particularly true of items of
associated equipment, including drive cables. A licensee should be vigilant to inspect and maintain associated
equipment in order to avoid component failures that could result in unnecessary radiation exposures to workers
and members of the public.
A licensee’s equipment inspection and maintenance program should prevent particular equipment problems that
may develop from excessive uses where harsh or abusive conditions exist that may cause a component to fail.
10 CFR 34.31, “Inspection and maintenance of radiographic exposure devices, transport and storage
containers, associated equipment, source changers, and survey instruments”, requires a licensee to perform
visual and operability checks on associated equipment before use on each day the equipment is to be used to
ensure that the equipment is in good working condition. If equipment problems are found, the equipment must
be removed from service until repaired. In addition, the licensee is required to have written procedures for
inspection and routine maintenance of associated equipment at intervals not to exceed three months or before
the first use thereafter to ensure the proper functioning of components important to safety. Replacement
components shall meet design specifications. If problems are found, the equipment must be removed from
service until repaired. Records are required for equipment problems and any maintenance performed.
Attachment 2
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 78
AVAILABILITY OF REFERENCE DOCUMENTS
Below are the titles of the reference documents along with the URLs and the ADAMS accession numbers (e.g.,
MLxxxxxxxxx)., if available. The URLs link directly to the documents that are posted on the NRC’s public web
site. For documents without an URL, NRC maintains an Agencywide Document Access and Management
System (ADAMS), which provides text and image files of NRC's public documents. These documents may be
accessed through the NRC's Public Electronic Reading Room on the Internet at http://www.nrc.gov/reading-
rm/adams.html. If you do not have access to ADAMS or if there are problems in accessing the documents
located in ADAMS, contact the NRC Public Document Room (PDR) Reference staff at 1-800- 397-4209, 301-
415- 4737, or by e-mail to [email protected]. If no URL or ADAMS accession number is indicated for the document
then send a written request for a single, paper copy of the document to the Office of Administration,
Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; or
contact the PDR noted above.
1. Federal Register notice (68 FR 41757, July 15, 2003), Denial of a petition for rulemaking [Docket No.
PRM-34-5, Amersham Corporation] ML050620568
2. 10 CFR Part 32, Specific domestic licenses to manufacture or transfer certain items containing
byproduct material http://www.nrc.gov/reading-rm/doc-collections/cfr/part032/
3. 10 CFR Part 34, Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial
Radiographic Operations http://www.nrc.gov/reading-rm/doc-collections/cfr/part034/
4. American National Standards Institute (ANSI) N432–1980, Radiological Safety for the Design and
Construction of Apparatus for Gamma Radiography, (ANSI N432) ML050840139
5. NRC Enforcement Policy http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html
6. NUREG-1556, Volume 3, Revision 1, Consolidated Guidance About Materials Licenses–Applications
for Sealed Source and Device Evaluation and Registration, (Final Report, April 2004) ML041340618
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v3/r1/
7. Inspection Procedure 87121, Industrial Radiography Programs, http://www.nrc.gov/reading-rm/doc-
collections/insp-manual/inspection-procedure/ip87121.pdf
8. NUREG-1556, Volume 2, Consolidated Guidance about Materials Licensees–Program-Specific
Guidance about Industrial Radiography Licenses (Final Report, August 1998)
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v2/
9. NUREG-1631, Source Disconnects Resulting from Radiography Drive Cable Failures (June 1998)
http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1997/in97091s1.html
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 79
Appendix G
Radiographer and Radiographer’s Assistant
Training
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 80
Radiographer’s Training
REFERENCE REQUIREMENT TRAINING CRITERIA
902 KAR 100:100 Training
Classroom Training – 40
hours in Length
Topics in 902 KAR 100:100 SECTION 14
Fundamentals of Radiation Safety
Characteristics of gamma radiation
Units of radiation dose and quantity of
radioactivity
Hazards of exposure to radiation
Levels of radiation from licensed material
Methods of controlling radiation dose
(time, distance, and shielding)
Radiation Detection Instruments
Use, operation, calibration and limitations
Survey techniques
Personnel monitoring equipment
Equipment to be Used
Operation and control of radiographic
exposure equipment, remote handling
equipment, storage containers and pictures
or models of source assemblies (pigtails)
Storage, control and disposal of licensed
material
Inspection and maintenance of equipment
Requirements of 902 KAR 100, ‘Kentucky
Radiation Protection Regulations’
Case Histories of Accidents in Radiography
On-the-Job Training- 2
months or 320 hours
Under the supervision of a qualified radiographer
Certification by a Certifying
Entity
Certified through a radiographer certification
program meeting the requirements of 10 CFR 34
Appendix A. See the following CRCPD website
for a listing of Industrial Radiography
Certification entities
(http://www.crcpd.org/IR.aspx#List of States)
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 81
902 KAR 100:100 Must Receive Copies of
and Instruction in:
902 KAR 100 Parts
019(www.lrc.state.ky.us/kar/902/100/019.htm)
040(www.lrc.state.ky.us/kar/902/100/040.htm)
070(www.lrc.state.ky.us/kar/902/100/070.htm)
100(www.lrc.state.ky.us/kar/902/100/100.htm)
165(www.lrc.state.ky.us/kar/902/100/165.htm)
The License
The Licensee's Operating & Emergency Procedures
Written Examination of
items listed above
Successful completion
902 KAR 100:100 Receive Equipment
Training
Training includes:
Exposure devices
Sealed sources
Associated equipment
Survey meters
Daily inspection
Demonstrate
Understanding in Use of
Equipment by Practical
Exam
Successful completion
902 KAR 100:100 Annual Refresher
Training
Review the following:
Radiation Safety review
New procedures or equipment
New rule requirements
Observations and deficiencies during audits and
discussion of any significant incidents or
accidents involving radiography
Employee questions
902 KAR 100:100 Records of Training and
Certification
Maintained in accordance with rule
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 82
Radiographer’s Assistant Training
REFERENCE REQUIREMENT TRAINING CRITERIA
902 KAR 100:100 Must Receive Copies of and
Instruction in:
902 KAR 100 Parts
019
040
070
100
165
The License
The Licensee's Operating & Emergency
Procedures
Written Examination of items
listed above
Successful completion
902 KAR 100:100 Receive Equipment Training
Training under the supervision of a
qualified radiographer that includes:
Exposure devices
Sealed sources
Associated equipment
Survey meters
Daily inspection
Demonstrate Understanding in
Use of Equipment by Practical
Exam
Successful completion
902 KAR 100:100 Annual Refresher Training Review the following:
Radiation Safety review
New procedures or equipment
New rule requirements
Observations and deficiencies during
audits and discussion of any significant
incidents or accidents involving
radiography
Employee questions
902 KAR 100:100 Records of Training and
Certification
Maintained in accordance with rule
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 83
Appendix H
Six-Month Radiographer/Radiographer's Assistant
Inspection Checklist
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 84
Six-Month Radiographer/Radiographer's Assistant
Inspection Checklist
Date: __________ Time: ________
Radiographic Location: ____________________________________
Radiographer/Radiographer’s Assistant:_________________________________________________________
Device Model No.: ___________________________ Serial No.: _________________________
Survey Meter Functionality: Yes No
Calibrated: Yes No Daily Source Check: Yes No
Dosimetry: OSLD, Film Badge, Or Similar Device and Pocket Dosimeter: Yes No
Pocket Dosimeter Calibrated: Yes No
Alarming Dosimeter: Yes No
Calibrated: Yes No
Daily Operational Check Performed: Yes No
Were other individuals working within the restricted area wearing film badges, OSLDs or
similar devices, dosimeters and alarming ratemeters?
Yes No
Was the restricted area posted with a "CAUTION (or DANGER) RADIATION AREA" sign(s)? Yes No
Was the restricted area properly controlled to prevent unauthorized entry? Yes No
Was the high-radiation area posted with a "CAUTION (OR DANGER) HIGH RADIATION
AREA" sign(s)?
Yes No
Was the Utilization Log properly filled out? Yes No
Did the radiographer/radiographer’s assistant have sufficient knowledge of safety rules? Yes No
Was the radiographer working with properly inspected and operable equipment? Yes No
Did the radiographer/radiographer’s assistant properly survey the camera? Yes No
Did the radiographer properly supervise the radiographer’s assistant? Yes No
Was the camera properly locked and secured to prevent unauthorized removal? Yes No
Was the restricted area properly controlled? Yes No
Was the high radiation area under continuous direct observation except where entry had
been prevented?
Yes No
Were radioactive isotopes stored properly and kept locked to prevent removal? Yes No
Was the storage area posted with a "CAUTION (or DANGER) RADIOACTIVE MATERIAL"
sign(s)?
Yes No
Did the radiographer/radiographer’s assistant possess and use a copy of the operating
and emergency procedures and KYDPH rules for protection against radiation?
Yes No
Were there any other safety items found to be lacking? If yes, explain in Remarks. Yes No
Remarks/Comments:
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 85
Appendix I
Radiation Protection Program Audit
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 86
Radiation Protection Program Audit
Date of this Audit:____________________ Date of Last Audit:____________________
Next Audit Date:____________________
Auditor_____________________________ Date____________________
(Signature)
Management Review___________________________ Date____________________
(Signature)
Organization and Scope of Program
A. Organizational structure. (specify any changes)
1. Matches license requirements. [L/C]
2. Multiple authorized locations of use and/or field sites authorized.
3. List of location(s) inspected - attached or reference.
4. Brief description of scope of activities, including types of equipment, types and quantities of use
involving radioactive material, frequency of use, staff size, etc.
B. Radiation Safety Officer.
1. Named on license. [L/C]
2. Fulfills duties as RSO. 902 KAR 100:100
3. Meets requirements. 902 KAR 100:100
C. Radiographers and radiographer's assistants named in documents. [L/C]
Training, Retraining, and Instructions to Workers
A. Instructions to workers. [902 KAR 100:165]
B. 902 KAR 100 Parts: 019, 040, 070, 100 and 165; the license; and operating and emergency procedures are
furnished to all radiographers and radiographer's assistants. [902 KAR 100:100]
C. Training program description the same as that submitted with license application or as amended?
[902 KAR 100:100]
1. Written tests completed by all radiographers and radiographer's assistants.
2. Oral tests.
3. All radiographers completed on-the-job training.
4. Periodic training program implemented.
5. Records maintained [902 KAR 100:100].
D. Workers cognizant of requirements for:
1. Radiation safety program. [902 KAR 100]
a. Occupational exposure annual limits. [902 KAR 100:019]
b. Public annual dose limits. [902 KAR 100:019]
2. 10% monitoring threshold. [902 KAR 100:019]
3. Dose limits to embryo/fetus and declared pregnant worker. [902 KAR 100:019]
4. Procedures for opening packages. [902 KAR 100:070]
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 87
Operating and Emergency Procedures
A. Procedures current? [902 KAR 100:100]
B. Procedures contain information specified. [902 KAR 100:100]
C. Procedures submitted to KYDPH. [L/C]
Internal Audits or Inspections
A. Audits/inspections of each radiographer and radiographer's assistants conducted at 6-month intervals or after
as appropriate. [902 KAR 100:100]
B. Equipment check before use each day. [902 KAR 100:100]
C. Equipment inspection and maintenance performed at 3-month intervals. [902 KAR 100:100]
D. Records maintained. [902 KAR 100:019, 902 KAR 100:040, 902 KAR 100:100]
Facilities
A. Permanent radiographic installation. [902 KAR 100:100]
1. High Radiation Area posted. [902 KAR 100:019]
2. Entrance controls are as described. [902 KAR 100:100]
a. Visible and audible radiation signals.
b. Visible signal actuates if entry is attempted when source is exposed.
c. Audible signal actuates if entry is attempted when source is exposed.
d. System tested daily before use with radiation source.
e. Records maintained for 3 years. [902 KAR 100:100]
B. Temporary High Radiation Area Entry Controlled. [902 KAR 100:100]
C. Storage Area
1. Storage Facilities as Described in license. [L/C]
2. Sources Locked in Devices. [902 KAR 100:100]
3. Devices secured to prevent tampering or unauthorized removal. [902 KAR 100:100]
Equipment
A. Radiography devices, source assemblies and source changers in use meet requirements. [902 KAR 100:100]
B. Associated equipment in use complies with requirements. [902 KAR 100:100]
C. Source changers and storage containers meet radiation level limits. [902 KAR 100:100]
D. Equipment exempted by specific license condition is used in accordance with license commitments and
authorization.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 88
Materials
A. Isotope, chemical/physical form, quantity and use as authorized on the license. [L/C]
B. All sealed sources not fastened to or contained in an exposure device are tagged. [902 KAR 100:100]
C. Leakage and contamination tests.
1. Sealed sources.
a. Leak test method approved. [902 KAR 100:100]
b. Leak tests performed at 6 month intervals. [902 KAR 100:100]
c. Leakage is less than 185 Becquerel (Bq) (0.005 microcuries).
2. Depleted uranium (DU) shielding with S-tubes.
a. Test every 12 months. [902 KAR 100:100]
b. DU is less than 185 Bq (0.005 microcuries).
3. Records maintained for 3 years. [902 KAR 100:100] D. Inventories
1. Conducted quarterly (not to exceed 3 months). [902 KAR 100:100]
2. Contain all required information. [902 KAR 100:100]
3. Records maintained for 3 years. [902 KAR 100:100]
3. Most recent inventory conducted on _________________
E. Utilization Logs
1. Utilization logs maintained. [902 KAR 100:100]
2. Contain all required information. [902 KAR 100:100]
Instrumentation
A. Describe the survey instruments possessed:
Model No. ________________Quantity________________
B. Capable of measuring 0.02 mSv (2 mrem)/hr through 0.01 Sv (1 rem)/hr. [902 KAR 100:100]
C. Operable and calibrated survey instruments available and used on each job (at least one survey instrument
per every exposure device). [902 KAR 100:100]
D. Calibration performed at intervals not to exceed six months or after servicing. [902 KAR 100:100]
E. Records maintained for 3 years. [902 KAR 100:100]
Radiation Surveys
A. Area or facility surveys conducted to show compliance with 902 KAR 100:100. [902 KAR 100:100]
B. Records maintained. [902 KAR 100:100]
C. Survey after each exposure, including device, guide tube, ensuring source has returned to the shielded
position. [902 KAR 100:100]
D. Survey of device when place in storage to ensure source is in shielded position. [902 KAR 100:100]
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 89
E. Protection of members of the public [902 KAR 100:019]
1. Adequate surveys made to demonstrate.
a. The TEDE to the individual likely to receive the highest dose does not exceed 0.1 mSv (100 mrem) in a
year;
Or
b. That if an individual were continuously present in an unrestricted area, the external dose would not
exceed 1 mSv (100 mrem) in a year. [902 KAR 100:019]
2. Unrestricted area radiation levels do not exceed 0.02 mSv (2 mrem) in any 1 hour. [902 KAR 100:019]
3. Records maintained. [902 KAR 100:019]
Personnel Radiation Protection
A. Dosimetry
1. Workers monitored as required. [902 KAR 100:100]
2. Exchange Frequency ________________ Supplier_______________________________
3. Verify supplier is NVLAP-approved. [902 KAR 100:100]
4. Dosimetry exchanged at required frequency. [902 KAR 100:100]
5. Dosimetry records maintained. [902 KAR 100:100]
B. Pocket Dosimeters and Electronic Personal Dosimeters [902 KAR 100:100]
1. Model No. ______________________ Range ______________________________
Model No. ______________________ Range ______________________________
2. Read and recorded at start of each shift.
3. Daily readings recorded.
4. Dosimeters checked for response (± 20%) at intervals not to exceed 12 months.
5. Off-scale dosimeter procedure and records.
C. Alarming Ratemeters [902 KAR 100:100]
1. Model No._____________________ Range ______________________________
2. Checked that alarm functions properly at start of each shift.
3. Preset at 5 mSv (500 mrem)/hr.
4. Calibrated to ±20% at intervals not to exceed 12 months.
5. Records maintained.
D. Dosimetry Reports
1. Reviewed by ___________________ Frequency ___________________________.
2. Reviewed personnel monitoring records for interval (from _________ to __________ ).
3. Maximum exposures: TEDE __________ extremity, other ____________.
4. NRC Form 5 (or equivalent). [902 KAR 100:019, 902 KAR 100:100]
5. Maximum exposures in compliance with annual limits. [902 KAR 100:019]
6. Fetal and Pregnant worker exposure. [902 KAR 100:019]
a. Worker declared pregnancy in writing during the audit interval.
b. If yes, licensee in compliance? Records maintained?
7. Dosimetry records maintained. [902 KAR 100:019]
8. Annual exposure reports given to workers? [902 KAR 100:165]
E. Radiation Protection Program [902 KAR 019]
1. Program includes provisions for keeping dose ALARA.
2. Procedures and engineering controls used to achieve ALARA.
3. Content and implementation reviewed annually by licensee.
4. Records of program reviews maintained.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 90
F. Planned Special Exposures (PSEs) [902 KAR 100:019]
1. PSEs performed? __________
2. If so, when, where and why? __________
3. Records maintained.
Receipt and Transfer of Radioactive Material [902 KAR 100:040]
A. Procedures established and followed for picking up, receiving, and opening packages.
B. Incoming packages surveyed.
C. Shipment of sources since last inspection.
1. Used container authorized by license or Certificate of Compliance (COC).
2. Transfers.
3. All sources surveyed before shipment and transfer.
D. Records of surveys and receipt/transfer maintained. [902 KAR 100:040]
Transportation [902 KAR 100:070 and 49 CFR 170-189]
A. Shipments are:
Delivered to common carriers.
Transported in company's private vehicle.
Both.
No shipments since last audit.
B. DOT HAZMAT training [49 CFR 172.700- 172.704]
C. Packages:
1. Authorized packages used. [49 CFR 173.415; 173.416]
2. Performance test records on file.
a. Special form sources. [49 CFR 173.476(a)]
b. DOT-7A packages. [49 CFR 173.415(a)]
3. COC's on file with NRC for Type B. [10 CFR 71.12(c)(1)]
4. Two labels with Transport Index, Nuclide, Hazard Class. [49 CFR 172.403; 172.441]
5. Properly marked (Shipping name, UN number, Package type, RQ, Name and address of consignee.
[49 CFR 172.301; 172.310; 172.324; 172.101]
6. Closed and sealed during transport. [49 CFR 173.475(f)]
D. Shipping papers
1. Prepared and used. [49 CFR 172.200(a)]
2. Proper (Shipping name, Hazard class, UN number, Quantity, Package type, Nuclide, RQ, Radioactive
material, Physical and chemical form, Category of label, TI, Shipper's name, Certification and signature,
Emergency response phone number, "Limited Quantity","Cargo Aircraft Only" if applicable). [49 CFR
172.200 - 172.204; 175.700]
3. Emergency Response Information required by 49 CFR 172 subpart G, 172.600 and 172.602 presented
along with the Shipping Paper, either on the document itself or as an attached document with specific
instructions for (1) Immediate hazards to health; (2) Risks of fire or explosion; (3) Immediate precautions
to be taken in the event of an accident or incident; (4) Immediate methods for handling fires; (5) Initial
methods for handling spills or leaks in the absence of fire; and (6) Preliminary first aid measures.
4. Readily accessible during transport (on seat next to driver or driver’s side door pouch).
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 91
E. Vehicles
1. Placarded. [49 CFR 172.504]
2. Cargo blocked and braced. [49 CFR 177.842(d)]
3. Proper overpacks (shipping name, UN number label, statement of inner packaging complies with
specification packaging). [49 CFR 171.15; 171.16]
F. Any transportation incidents reported to DOT National Response Center [49 CFR 171.15; 171.16]
Auditor's Independent Measurements
A. Survey Instrument:___________________________
Serial No.:_________________
Last Calibration:____________
B. Auditor's measurements were compared with audited person's measurement
C. Describe the type, location, and results of measurements, attach a diagram/survey sheet and refer to this
section
Notifications and Reports
A. Reports to individuals, public and occupational, monitored to show compliance [902 KAR 100:019]
B. Theft or loss [902 KAR 100:019]
C. Incidents [902 KAR 100:040]
D. Overexposures and high radiation levels [902 KAR 100:019]
E. Annual reports furnished to KYDPH
F. Reporting of defects and non-compliance [902 KAR 100:100]
Posting and Labeling
A. Radiation areas [12VAC5-481-860]
B. High radiation areas [12VAC5-481-860]
C. Use or storage areas [12VAC5-481-860]
D. Containers or devices labeled [12VAC5-481-880, 12VAC5-481-1290]
E. Notice to Employees, Form KR-441 [12VAC5-481-2260 C]
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 92
Recordkeeping for Decommissioning [902 KAR 100:042]
A. Records in independent and identifiable location
B. Records include all required data
Bulletins and Information Notices
A. Communications received and reviewed
B. Appropriate response to Information Notices
Special License Conditions or Issues
Evaluate special license conditions for data, actions
Performance Evaluation Factors
These indicators may provide an indication of the status of the Radiation Safety Program as perceived by
management.
A. Lack of senior management involvement with the radiation safety program and/or RSO oversight
B. RSO too busy with assignments other than radiation safety
C. Insufficient staffing
D. Radiation Safety Committee fails to meet or functions inadequately
E. Inadequate consulting service or inadequate audits
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 93
Appendix J
Procedure for Calibrating Survey Instruments
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 94
Procedure for Calibrating Survey Instruments
A. Sealed source(s) used for calibrating survey instruments should:
1. Approximate a point source
2. Have its exposure rate at a given distance traceable by documented measurements to a standard certified to
be within +/- 5% accuracy by NIST
3. Approximate the same photon energy (Ir-192, Co-60) as the source to be used in the radiography device.
4. Be of sufficient strength to give an exposure rate of about 0.3 mSv/hr (30 mrem/hr) at 100 cm. (85 mCi of
Cs-137 or 21 mCi of Co-60).
B. Use the inverse square and radioactive decay law to correct changes in exposure rate due to source decay or
different distances from the source.
C. Record survey meter calibration data and maintain written records for each instrument being used to satisfy
regulatory requirements. Survey meter calibration reports should indicate the procedure used and the data
obtained. Calibration records should contain the following information and must be maintained three (3)
years from date of calibration of each instrument:
1. Owner or user identification, including name, address, and person to be contacted;
2. Instrument description that includes manufacturer, model number, serial number, and type of detector;
3. Calibration source description that includes exposure rate, indicated exposure rate at a specified distance
on a specified date, and the calibration procedure;
4. Each calibration point identifying the calculated exposure rate, the indicated exposure rate, the deduced
correction factor, and the scale selected on the instrument;
5. Exposure reading indicated with the instrument in the ‘battery check’ mode, if available;
6. Angle between the radiation flux field and the detector (parallel, perpendicular); Note: Internal detectors should specify angle between radiation flux field and a specified surface of the instrument
7. For detectors with removable shielding, note whether the shielding was in place or removed during the
calibration procedure;
8. Include person's name who performed the calibration and the date on which the calibration was
performed;
D. A single point on a survey meter scale can be considered satisfactorily calibrated if the indicated exposure
rate differs from the calculated exposure rate by less than 10%.
Note: Three kinds of scales are frequently used on radiation survey meters:
1. Linear Scale: Meters on which the user selects a linear scale must be calibrated at no less than two
points on each scale. The points should be at approximately 1/3 and 2/3 of the decade.
2. Multidecade Logarithmic Scale: Meters that have a multidecade logarithmic scale must be calibrated
at no less than one point on each decade and no less than two points on one of the decades. Those
points should be approximately 1/3 and 2/3 of the decade.
3. Automatically Ranging Digital Display: Meters that have a device for indicating rates must be
calibrated at no less than one point on each decade and at no less than two points on one of the
decades. Those points should be at approximately 1/3 and 2/3 of the decade.
E. Scales in excess of 10 mSv/hr (1,000 mrem/hr) need not be calibrated. However, such scales should be
checked for operation and approximately correct response.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 95
F. The following information should be attached to the instrument as a calibration sticker or tag:
1. Source that was used to calibrate the instrument
2. A calibration chart or graph for each scale or decade of a survey meter that is greater than +/ 20% of the
actual values identifying the average correction factor, or a note indicating that scale was checked only for
function or is inoperative.
3. Date of calibration
4. Date survey instrument is due calibration
5. Name or initials of individual calibrating instrument.
Note: Detailed information about survey instrument calibration may be obtained by referring to ANSI N323-
1978, "Radiation Protection Instrumentation Test and Calibration". Copies may be obtained from the
American National Standards Institute, 1430 Broadway, New York, NY 10018.
NUREG 1556, Volume 18 ‘Program-Specific Guidance About Service Provider Licenses’ is available from the
NRC website at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v18/ .
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 96
Appendix K
Requests to Perform Leak Testing and
Sample Analysis
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 97
Requests to Perform Leak Testing and Sample Analysis
A. Requests to Perform Leak Testing and Sample Analysis
1. Identify the individual who will make the analysis and provide his or her qualifications to make
quantitative measurements of radioactivity.
2. Specify how and where test samples will be taken on the radiography device. Describe materials used and
methods of handling samples to prevent or minimize exposure to personnel.
3. Specify the type of instrument(s) that will be used for measurement, the counting efficiency, and minimum
levels of detection for each radionuclide to be measured.
Note: An instrument capable of making quantitative measurements should be used; hand-held survey meters
will not normally be considered adequate for measurements.
4. Specify the standard sources used to calibrate the instrument; for each, specify the radionuclide, quantity,
accuracy, and tractability to primary radiation standards.
Note: Accuracy of standards should be within ±5% of the stated value and traceable to a primary radiation
standard such as those maintained by the National Institutes of Standards and Technology (NIST).
NUREG 1556, Volume 18 ‘Program-Specific Guidance About Service Provider Licenses’ is available at
the NRC website: http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v18/ , or from
DHFS upon request.
5. Include a sample calculation for conversion of the measurement data to Bq (or microcuries).
6. Provide instructions on actions to take and persons to be notified if sources are found to be leaking.
B. Procedure for Performing Leak Testing and Analysis
1. For each source to be tested, list identifying information such as radiography device serial number,
radionuclide, activity.
2. If available, use a survey meter to monitor exposure.
3. Prepare a separate wipe sample (e.g., cotton swab or filter paper) for each source.
4. Number each wipe to correlate with identifying information for each source.
5. Wipe the most accessible area where contamination would accumulate if the sealed source were leaking.
6. Using the instrument identified to and approved by KYDPH, count and record background count rate.
7. Check the instrument's counting efficiency using standard source of the same radionuclide as the source
being tested or one with similar energy characteristics.
8. Calculate efficiency.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 98
9. Count each wipe sample; determine net count rate.
10. For each sample, calculate and record estimated activity in Bq (or microcuries).
11. Sign and date the list of sources, data and calculations.
12. If the wipe test activity is 185 Bq (0.005 microcurie) or greater, notify the RSO, so that the source can
be withdrawn from use and disposed of properly. Also notify KYDPH.
C. Sampling and Analysis for Depleted Uranium as a Result of S-tube Breakthrough
Note: As an ALARA and safety measure, the source should be transferred to a source changer before the S-
tube is tested for breakthrough.
1. The wipe test sample should be obtained from the areas of the tube where wear is likely to be most
severe, at the first curve nearest the ends of the radiography device. The sample should be analyzed for
alpha contamination. Alpha contamination present indicates that wear has broken through the S-tube to
expose the depleted uranium.
2. Alpha counting sensitivity should be able to detect 185 Bq (0.005 microcuries) of contamination.
3. A worn S-tube could create equipment operating difficulties. Upon verification of the presence of alpha-
particle emitting uranium, the radiographic exposure device should be removed from use until an
evaluation of the wear of the S-tube has been made. Should the evaluation reveal that the S-tube is worn
through, the device may not be used again. No user repairs are permitted.
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Appendix L
Guidance for Demonstrating That Individual
Members of the Public Will Not Receive Doses
Exceeding the Allowable Limits
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Guidance for Demonstrating That Individual Members of the Public
Will Not Receive Doses Exceeding the Allowable Limits
A. Licensees must ensure that:
1. The radiation dose received by individual members of the public resulting from the licensee’s possession
and/or use of licensed materials does not exceed 1 mSv (100 mrem) in one calendar year.
Members of the public include persons who live, work, or may be near locations where industrial
radiography devices are used or stored and employees whose assigned duties do not include the use of
licensed materials and who work in the vicinity where devices are used or stored.
2. The radiation dose in unrestricted areas does not exceed 0.02 mSv (2 mrem) in any one hour.
Typical unrestricted areas may include offices, shops, laboratories, areas outside buildings, property, and
nonradioactive equipment storage areas. The licensee does not control access to these areas for purposes
of controlling exposure to radiation or radioactive materials. However, the licensee may control access to
these areas for other reasons such as security.
3. Licensees must show compliance with both portions of the rule. Radiographic operations at temporary
jobsites must be demonstrated to have doses to the public in unrestricted areas that do not exceed 0.02
mSv (2 mrem) in any one hour. For storage areas and permanent radiographic facilities, calculations or a
combination of calculations and measurements (e.g., using an environmental TLD) are often used to
prove compliance with levels of 0.02 mSv (2 mrem) in any one hour and 1mSv (100 mrem) in a calendar
year.
B. Calculation Method
1. For ease of use by most industrial radiography licensees, the examples in this Appendix use conventional
units. The conversions to SI units are as follows: 1 foot (ft) = 0.305 meter (m); 1 mrem = 0.01 mSv.
2. The calculation method takes a tiered approach, going through a three-part process starting with a worst
case situation and moving toward more realistic situations. It makes the following simplifications: (1)
each device is a point source, (2) typical radiation levels encountered when the source is in the shielded
position are taken from either the Sealed Source & Device (SSD) Registration Sheet, the maximum dose
levels allowed for a transport package (exposure device) labeled YELLOW III, or the manufacturer's
literature, and (3) no credit is taken for any shielding found between the devices and the unrestricted
areas.
3. Part 1 of the calculation method is simple but conservative. It assumes that a member of the public is
present 24 hours a day, and it uses only the inverse square law to determine if the distance between the
device and the affected member of the public is sufficient to show compliance with the public dose
limits. Part 2 considers not only distance, but also the time that a member of the public is actually in the
area under consideration. Part 3 considers distance and the portion of time that both the device and the
affected member of the public are present. Part 4 considers the distance, the portion of time that both the
device and the affected member of the public are present and the shielding provided by the structural
materials or shielding materials specifically added by the licensee. Using this approach, licensees make
only those calculations that are needed to demonstrate compliance. In many cases, licensees will need to
use the calculation method through Part 1 or Part 2. These calculations typically result in higher
radiation levels than would exist at typical facilities, but provide a method for estimating conservative
doses which could be received.
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C. Example 1
1. To better understand the calculation method, Mo-Rad, Inc., a hypothetical radiography licensee, is
demonstrated. Yesterday, the company's president noted that the new device storage area is close to his
secretary's desk and he asked Joe, the Radiation Safety Officer (RSO), to determine if the company is
complying with KYDPH regulations.
2. The secretary's desk is near the wall separating the reception area from the designated, locked device
storage area, where the company is storing its two devices. Joe measures the distances from each device
to the wall and assumes that each device would have the maximum dose rate allowed under KYDPH rule
or DOT regulations: 2 mSv/hr (200 mrem/hr) on the surface and 0.1 mSv/hr (10 mrem/hr) at one meter.
D. Findings
1. Upon his inspection, Joe found that there were two sources in the room. One Ir-192 device (Type B
container) had a reading of 10 mrem/hr at 1 meter (3.3 ft) and was 12 ft from the secretary’s chair. The
other was a Co-60 device (Type B container) had a reading of 10 mrem/hr at 1 meter (3.3 ft) and was 18
ft from the secretary’s chair.
E. Example 1: Part 1
1. Joe's first thought is that the distance between the devices and the secretary's chair may be sufficient to
show compliance with the regulation in 10 CFR 20.1301. So, taking a worst case approach, he assumes:
1) the devices are constantly present (i.e., 24 hr/d), 2) both devices remain in storage with no other use,
and 3) the secretary is constantly sitting in the desk chair (i.e., 24 hr/d). Joe proceeds to calculate the dose
she might receive hourly and yearly from each device, as shown in Tables 10 and 11 below.
F. Table 10: Calculation Method, Part 1: Hourly and Annual Dose Received from Device 1
Step No. Description Device 1 Input Data Results
1 Dose received in an hour at known distance from
device (e.g., from manufacturers data), in mrem/hr
10 10
2 Square of the distance (ft) at which the Step 1 rate
was measured, in ft2
(3.3)2 10.9
3 Square of the distance (ft) from the device the
secretary's desk in an unrestricted area, in ft2
(12)2 144
4 Multiply the results of Step 1 by the results of Step
2 (this is an intermediate result)
10 x 10.9 109
5 Divide the result of Step 4 by the result of Step 3 to
calculate the dose received by an individual at the
secretary's desk, HOURLY DOSE RECEIVED
FROM DEVICE 1, in mrem in an hour.
109/144
0.76
6 Multiply the result of Step 5 by 24 hr/d x 365 d/yr =
MAXIMUM ANNUAL DOSE RECEIVED FROM
DEVICE 1, in mrem in a year.
0.76 x 24 x 365
6,630
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G. Table 11: Calculation Method, Part 1: Hourly and Annual Dose Received from Device 2
Step No. Description Device 1 Input Data Results
1 Dose received in an hour at known distance from
device (e.g., from manufacturers data), in mrem/hr
10 10
2 Square of the distance (ft) at which the Step 1 rate
was measured, in ft2
(3.3)2 10.9
3 Square of the distance (ft) from the device the
secretary's desk in an unrestricted area, in ft2
(18)2 324
4 Multiply the results of Step 1 by the results of Step 2
(this is an intermediate result)
10 x 10.9 109
5 Divide the result of Step 4 by the result of Step 3 to
calculate the dose received by an individual at the
secretary's desk, HOURLY DOSE RECEIVED
FROM DEVICE 2, in mrem in an hour.
109/324
0.34
6 Multiply the result of Step 5 by 24 hr/d x 365 d/yr =
MAXIMUM ANNUAL DOSE RECEIVED FROM
DEVICE 2, in mrem in a year.
0.34 x 24 x 365
2,950
H. To determine the total hourly and total annual dose received, Joe adds the pertinent data from the
preceding tables.
Table 12: Calculation Method, Part 1: Total Hourly and Annual Dose Received from Devices 1 and 2
Step No. Description Device 1 Device 2 Sum
7 TOTAL HOURLY DOSE RECEIVED
from Step 5 of Tables 9 and 10, in mrem
in an hour
0.76
0.34
0.76 + 0.34 = 1.1
8 TOTAL ANNUAL DOSE RECEIVED
from Step 6 of Tables 10 and 11, in mrem
in a year
6,630
2,950
9,580
Note: The Sum in Step 7 demonstrates compliance with the limit of 2 mrem in any one hour. Reevaluate if
assumptions change. If the Sum in Step 8 exceeds 100 mrem/yr, proceed to Part 2 of the calculational method. At
this point, Joe is pleased to see that the total dose that an individual could receive in any one hour is only 1.1 mrem in
an hour, but notes that an individual could receive a dose of 9,580 mrem in a year, much higher than the 100 mrem
limit.
I. Example 1: Part 2
1. Joe reviews his assumptions and recognizes that the secretary is not at the desk 24 hr/d. He decides to
make a realistic estimate of the number of hours the secretary sits in the chair at the desk, keeping his
other assumptions constant (i.e., the devices are constantly present (i.e., 24 hr/d), both devices remain in
storage with no other use). He then recalculates the annual dose received.
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2. Table 13: Calculation Method, Part 2: Annual Dose Received from Devices 1 and 2
Step No. Description Results
9 A. Average number of hours per day that individual spends in
area of concern (e.g., secretary sits at desk 5 hr/day; the
remainder of the day the secretary is away from the desk area
copying, filing, etc.)
B. Average number of days per week in area (e.g., secretary is
part time and works 3 days/week)
C. Average number of weeks per year in area (e.g., secretary
works all year )
5
3
52
10 Multiply the results of Step 9.A. by the results of Step 9.B. by the
results of Step 9.C. = AVERAGE NUMBER OF HOURS IN
AREA OF CONCERN PER YEAR
5 x 3x 52 = 780
11 Multiply the sum in Step 7 by the results of Step 10 = ANNUAL
DOSE RECEIVED FROM DEVICES CONSIDERING
REALISTIC ESTIMATE OF TIME SPENT IN AREA OF
CONCERN, in mrem in a year
1.1 x 780 = 860
Note: If Step 11 exceeds 100 mrem in a year, proceed to Part 3 of the calculation method.
3. Although Joe is pleased to note that the calculated annual dose received is significantly lower, he realizes
it still exceeds the 100 mrem in a year limit.
J. Example 1, Part 3
1. Again Joe reviews his assumptions and recognizes that the devices are not always in storage when the
secretary is seated at the desk. As he examines the situation, he realizes he must consider each device
individually.
2. Summary of Information: Device #1 (Ir-192 Exposure Device) is located in the storage area overnight
and used every day at temporary jobsites all year long; it is returned to the storage location at the end of
each day meaning it is only present for the secretary’s first and last hours of work each day. Device #2
(Co-60 Exposure Device) is in the storage area continuously (24 hr/d) for 8 months of the year and at a
temporary jobsite for the remaining 4 months. The secretary is sitting at the desk 5 hours/day, 3
days/week and 52 weeks/year.
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3. Table 14: Calculation Method, Part 3: Annual Dose Received from Devices 1 and 2
Step No. Description Device 1 Device 2
12 Average number of hours per day device is in storage
while secretary is present
2 5
13 Average number of days per week device is in storage
while secretary is present
3 3
14 Average number of weeks per year device is in storage
while secretary is present
52 32
15 Multiply the results of Step 12 by the results of Step 13 by
the results of Step 14 = TOTAL HOURS EACH DEVICE
IS STORED PER YEAR WHILE SECRETARY IS
PRESENT
2x3x52 = 312
5x3x32=480
16 Multiply the results of Step 15 by the results of Step 7 =
ANNUAL DOSE RECEIVED FROM EACH DEVICE, in
mrem in a year
312x0.76=237
480x0.34=163
17 Sum the results of Step 16 for each device = TOTAL
ANNUAL DOSE RECEIVED CONSIDERING
REALISTIC ESTIMATE OF TIME SPENT IN AREA OF
CONCERN AND TIME DEVICE IS IN STORAGE, in
mrem in a year
237+163=400
Note: If the result in Step 17 is greater than 100 mrem/yr, the licensee must take corrective actions.
4. Joe notes that the result in Step 17 does not show compliance with the 100 mrem/yr limit. Since the result
in Step 17 is higher than 100 mrem/yr, then Joe has to consider one or more of the following:
Consider whether the assumptions used to determine occupancy and the time each device is in storage
are accurate, revise the assumptions as needed, and recalculate using the new assumptions.
Calculate the effect of any shielding located between the device storage area and the secretarial
workstation. Listed below are typical half-value layers (HVL) for Ir-192 and Co-60.
5. Table 15: Half Value Layers (HVL) for Typical Shielding Materials
Steel HVL (inches) Lead Concrete
Ir-192 0.5 0.25 1.7
Co-60 0.8 0.5 2.1
Take corrective action (e.g., move devices within storage area, move the storage area, move the
secretarial workstation) and perform new calculations to demonstrate compliance.
Designate the area outside the storage area as a restricted area and the secretary as an occupationally
exposed individual. This would require controlling access to the area for purposes of radiation
protection and training the secretary as required by 10 CFR 19.12.
K. Example 1, Part 4
1. Joe decides to take into account the amount of shielding provided by the wall between the secretary's desk
and the storage area where the two devices are located. The wall between the secretary's office and the
storage area is a 4 inch thick concrete fire wall.
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2. Table 16: Calculation Method, Part 4: Annual Dose Received from Devices 1 and 2
Step No. Description Device 1 Device 2
18 Annual dose received from each device from Step 15 237 163
19 Number of HVLs (Thickness of shielding
material/Thickness for one HVL); If more than one
shielding material, need to evaluate each shielding
material separately by type of radionuclide
4.0/1.7 = 2.35
4.0/2.1 = 1.9
20 Fraction of radiation dose transmitted through shield:
0.5 (Total Number of HVLs); If more than one
shielding material, then sum the number results from
Step 19 by radionuclide
0.5(2.35) = 0.2
0.5(1.9) = 0.27
21 Multiply the results of Step 20 by the results of Step 18
= ANNUAL DOSE RECEIVED FROM EACH
DEVICE, in mrem in a year
0.2 x 237 = 47
0.27 x 163 = 44
22 Sum the results of Step 21 for each device = TOTAL
ANNUAL DOSE RECEIVED CONSIDERING
REALISTIC ESTIMATE OF TIME SPENT IN AREA
OF CONCERN, TIME DEVICE IS IN STORAGE
AND SHIELDING OF STRUCTURAL MATERIALS,
in mrem in a Year
47 + 44 = 91
Note: If the result in Step 22 is greater than 100 mrem/yr, the licensee must take corrective actions.
3. Joe is glad to see that the results in Step 22 show compliance with the 100 mrem in a calendar year limit.
4. Note that in the example, Joe evaluated the unrestricted area outside only one wall of the device storage
area. Licensees also need to make similar evaluations for other unrestricted areas and to keep in mind the
ALARA principal, taking reasonable steps to keep radiation dose received below regulatory
requirements. In addition, licensees need to be alert to changes in situations (e.g., moving any of the
devices closer to the secretarial workstation, adding a device to the storage area, changing the secretary to
a full-time worker, or changing the estimate of the portion of time spent at the desk) and to perform
additional evaluations, as needed.
RECORD KEEPING: 12VAC5-481-1050 requires licensees to maintain records demonstrating
compliance with the dose limits for individual members of the public.
L. Combination Measurement - Calculation Method
1. This method, which allows the licensee to take credit for shielding between the device and the area in
question, begins by measuring radiation levels in the areas, as opposed to using manufacturer-supplied
rates at a specified distance from each device. These measurements must be made with calibrated survey
meters sufficiently sensitive to measure background levels of radiation. However, licensees must exercise
caution when making measurements with currently calibrated radiation survey instruments. A maximum
dose of 1 mSv (100 mrem) received by an individual over an interval of 2080 hours (i.e., a work year of
40 hr/wk for 52 wk/yr) is equal to less than 0.5 microsievert (0.05 mrem) per hour.
This rate is well below the minimum sensitivity of most commonly available G-M survey instruments.
2. Instruments used to make measurements for calculations must be sufficiently sensitive. An instrument
equipped with a scintillation-type detector (e.g., NaI(Tl)) or a micro-R meter used in making very low
gamma radiation measurements should be adequate.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 106
3. Licensees may also choose to use environmental TLDs. TLDs used for personnel monitoring (e.g., LiF)
may not have sufficient sensitivity for this purpose. Generally, the minimum reportable dose received is
0.1 mSv (10 mrem). Suppose a TLD monitors dose received and is changed once a month. If the
measurements are at the minimum reportable level, the annual dose received could have been about 1.2
mSv (120 mrem), a value in excess of the 1 mSv/yr (100 mrem/yr) limit. If licensees use TLDs to evaluate
compliance with the public dose limits, they should consult with their TLD supplier and choose more
sensitive TLDs, such as those containing CaF2 that are used for environmental monitoring in unrestricted
areas next to the device storage area for monitoring. This direct measurement method would provide a
definitive measurement of actual radiation levels in unrestricted areas without any restrictive assumptions.
Records of these measurements can then be evaluated to ensure that rates in unrestricted areas do not
exceed the 1 mSv/yr (100 mrem/yr) limit.
M. Example 2
1. As in Example 1, Joe is the RSO for Mo-Rad, Inc., a radiography licensee. The company has two devices
stored in a designated, locked storage area that adjoins an unrestricted area where a secretarial
workstation is located. See D for information. Joe wants to see if the company complies with the public
dose limits at the secretarial station.
2. During the winter while all the devices were in storage, Joe placed an environmental TLD badge in the
secretarial workspace for 30 days. Joe chose a winter month so he did not have to keep track of the
number of hours that each device was in the storage area. The TLD processor sent Joe a report indicating
the TLD received 100 mrem.
3. Table 17: Combination Measurement - Calculation Method
Step No. Description Input Data and Results
Part 1
1 Dose received by OSL, in mrem 100
2 Total hours OSL exposed 224 hr/d x 30 d/month =
720
3 Divide the results of Step 1 by the results of Step 2
to determine HOURLY DOSE RECEIVED, in
mrem in an hour
0.14
4 Multiply the results of Step 3 by 365 d/yr x 24 hr/d
= 8760 hours in one year = MAXIMUM
ANNUAL DOSE RECEIVED FROM DEVICES,
in mrem in a year
365 x 24 x 0.14 = 8760 x
0.14 = 1226
Part 2
Adjust for realistic estimates of the time the secretary spends in the area as in Part 2 of
Example 1.
Part 3
Adjust for realistic estimates of time devices spend in area of concern as in Part 3 of
Example 1.
Note: For the conditions described above, Step 3 indicates that the dose received in any one hour is less than the 2
mrem in any one hour limit. However, if there are any changes, then the licensee would need to reevaluate the
potential doses which could be received in any one hour. Step 4 indicates that the annual dose received would be
much greater than the 100 mrem in a year allowed by the rule.
4. In Step 2, Joe can adjust for a realistic estimate of the time the secretary spends in the area as he did in
Part 2 of Example 1.
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5. If the results of Joe's evaluation in Part 2 show that the annual dose received in a year exceeds 100 mrem,
then he can make adjustments for realistic estimates of the time spent in the area of concern while the
devices are actually in storage as in Part 3 of Example 1. (Recall that the TLD measurement was made
while all the devices were in storage -- i.e., 24 hr/d for the 30 days that the TLD was in place.)
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Appendix M
Information for Applicants to Consider When
Developing Procedures for Operating
Radiography Equipment
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 109
Information for Applicants to Consider When Developing
Procedures for Operating Radiography Equipment
A. Crank-out Device
1. Locate the source shield at the desired distance from the object to be radiographed.
2. Mount the source tip firmly, using jigs or other attachments, with the tip in the exact exposure position.
3. Locate the control unit at the maximum distance (25 feet or 7.6 meters) from the source shield with the
control tubes laid out as straight as possible.
4. Join the control cable to the unit following the manufacturer's instructions.
5. Establish and post the restricted area and high radiation area.
6. Unlock the device.
7. Turn the hand crank steadily to move the source out of the source shield to the exposure position.
8. Survey the perimeter of the restricted area to be sure that radiation levels do not exceed 0.02 mSv (2
mrem) in any one hour.
9. Maintain continuous visual surveillance over the restricted area during an exposure, keeping all persons
from entering.
10. After completing the exposure, retract the source by turning the crank until the "safe" position is
indicated.
11. Approach the device with the survey meter and survey the entire circumference of the device and the
guide tube to determine that the source is in a shielded position.
12. Lock the device and remove the key.
B. Pipeliner Device
1. Establish and post the restricted area and high radiation area.
2. Unlock the device.
3. Stand as far away as possible and out of the direction of the beam and expose the source
4. Survey the perimeter of the restricted area to be sure that the radiation levels do not exceed 0.02 mSv (2
mrem) in any one hour.
5. Maintain continuous visual surveillance over the restricted area during an exposure, keeping all persons
from entering.
6. After completing the exposure, return the source to the shielded position.
7. Survey the device to determine that the source is in a shielded position.
8. Lock the device.
Note: KYDPH considers the following very important: surveys of the restricted area, continuous surveillance of the
restricted area during an exposure, the survey of the device and guide tube, and locking the device.
C. Source Exchange
1. Removing the Old Source
Caution: Always use a calibrated, operable survey meter while performing a source exchange!
a. Survey the shipping container upon receipt with a survey meter. Note that the surface reading should not
exceed 2 mSv/hr (200 mem/hr).
b. Attach the end of the source guide tube to the exposure device.
c. Connect the other end of the source guide tube to the empty side of the source changer.
d. Unlock the empty side of the source changer.
e. Unlock the camera and crank out the source from the camera into the source changer.
f. Survey the source changer and guide tube to verify that the source is in the safe position.
g. Lock the source changer.
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h. Disconnect the source guide tube and drive cable to the source pigtail. Replace the dust cap on the
source changer.
i. Remove the source identification plate from the exposure device and affix the plate to the side of the
source changer loaded with the old source.
2. Installing the New Source
a. Remove the dust cap on the source changer lock body identified with the new source tag.
b. Align the camera and source guide tube with the source changer.
c. Connect the new source to the drive cable.
d. Connect the source guide tube to the source changer.
e. Unlock the source changer and retract the new source into the exposure device.
f. Survey the exposure device and guide tube to assure that the source is in the safe position.
g. Lock the exposure device.
h. Disconnect the source guide tube and drive accessories.
i. Affix the new source identification plate on the exposure device.
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Appendix N
Transportation
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Transportation
The following are the major areas in DOT regulations most relevant for transporting radiographic exposure
devices and source exchangers that are shipped as Type B quantities are:
A. Table of Hazardous Materials and Special Provisions [49 CFR 172.101]
1. 49 CFR 172.101 - Hazardous Materials Table [proper shipping name, hazard class, identification number]
2. Table 2, Appendix A, 49 CFR 172.101 - List of Hazardous Substances and Reportable Quantities [for
radionuclides]
B. Shipping Papers - 49 CFR 172.200
1. 49 CFR 172.201 - General entries [on shipping papers]
2. 49 CFR 172.202 - Description of hazardous material on shipping papers
3. 49 CFR 172.203 - Additional description requirements
4. 49 CFR 172.204 - Shipper's certification [if applicable]
C. Package Markings - 49 CFR 172.300
1. 49 CFR 172.301 - General marking requirements for non-bulk packaging
2. 49 CFR 172.304 - Marking requirements
3. 49 CFR 172.310 - Radioactive material [Type B]
4. 49 CFR 172.324 - Hazardous substances in non-bulk packaging [designation of "reportable quantities"
with the letters "RQ"]
D. Package Labeling - 49 CFR 172.400
1. 49 CFR 172.400(a) - General labeling requirements
2. 49 CFR 172.403 - Radioactive materials [types and contents of labels]
3. 49 CFR 172.406 - Placement of labels
E. Placarding of Vehicles - 49 CFR 172.500
1. 49 CFR 172.504 - General placarding requirements
2. 49 CFR 172.516 - Visibility and display of placards
3. 49 CFR 172.556 - RADIOACTIVE placard
F. Emergency Response Information - Subpart G
1. 49 CFR 172.600 - Applicability and general requirements
2. 49 CFR 172.602 - Emergency response information
3. 49 CFR 172.604 - Emergency response telephone number
G. Training - Subpart H
1. 49 CFR 172.702 - Applicability and responsibility for training and testing [for HAZMAT employees]
2. 49 CFR 172.702 - Training requirements (includes types of training, when it must be conducted, need for
refresher training every 3 years, recordkeeping)
H. Security Plans – 49 CFR 172
1. 49 CFR 172.800, 49 CFR 172.802: Purpose and applicability, components of a security plan;
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 113
I. Shippers - General Requirements for Shipments and Packaging - 49 CFR 173
1. 49 CFR 173.25 - Requirements for use and labeling of overpacks
2. 49 CFR 173.403 - Definitions
3. 49 CFR 173.411 - General design requirements
4. 49 CFR 173.413 - Additional design requirements for Type B packages
5. 49 CFR 173.416 - Authorized Type B packages [includes packaging certification requirements]
6. 49 CFR 173.441 - Radiation levels
7. 49 CFR 173.471 - Additional requirements for Type B packages approved by NRC
8. 49 CFR 173.476 - Approval of special form radioactive materials [includes requirement for
documentation of special form status]
J. Carriage by Public Highway - 49 CFR 177
1. 49 CFR 177.817 - Shipping paper [location of shipping papers during transport]
2. 49 CFR 177.842 - Class 7 (radioactive) material [includes requirement for blocking and bracing during
transport]
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 114
Labeling Packages (49 CFR 172.400-450)
NOTE: IAEA, ICAO, and IMO may require additional hazard communication information for international shipments. This table must
not be used as a substitute for the DOT and NRC regulations on the transportation of radioactive materials.
• Labeling is required to be: (1) placed near the required marking of the proper shipping name, (2) printed or affixed to the
package surface, (3) in contrast with its background, (4) unobscured by markings or attachments, (5) within color, design,
and size tolerance, and (6) representative of the HAZMAT contents of the package.
• Two labels are required on opposite sides of the package, excluding the bottom.
Determination of Required Label
Size:
Sides:
≥ 100 mm
Border:
5-6.3 mm
49 CFR 172.436
49 CFR 172.438
49 CFR 172.440
WHITE-I YELLOW-II YELLOW-III
Required
when:
Surface radiation level ≤ 0.005
mSv/hour (0.5 mrem/hour)
0.005 mSv/hour (0.5 mrem/hour)
< surface radiation level ≤
0.5 mSv/hour (50 mrem/hour)
0.5 mSv/hour (50 mrem/hour) <
surface radiation level ≤
2 mSv/hour (200 mrem/hour)
Or: TI = 0 [1 meter dose rate < 0.5 mrem/hour]
TI ≤ 1 [1 meter dose rate ≤ 1 mrem/hour]
1 < TI ≤ 10 [1 meter dose rate ≤ 10 mrem/hour]
Content on Radioactive Labels
RADIOACTIVE label must contain (entered using a durable, weather-resistant means):
(1) The radionuclides in the package. Symbols (e.g., Ir-192) are acceptable.
(2) The activity in SI units (e.g., Bq, TBq) or both SI units with customary units (e.g., Ci, mCi) in parenthesis.
(3) The Transport Index (TI) in the supplied box. The TI is entered only on YELLOW-II and YELLOW-III labels.
Some Special Considerations for Labeling Requirements
• Radioactive material, excepted packages (e.g., Limited Quantity, Radioactive Instrument and Article) are excepted from
labeling.
• The “Cargo Aircraft Only” label is typically required for radioactive materials packages shipped by air [§172.402(c)]
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Marking Packages (49 CFR 172.300-308)
NOTE: IAEA, ICAO, and IMO may require additional hazard communication information for international shipments. This table must
not be used as a substitute for the DOT and NRC regulations on the transportation of radioactive materials.
Always Required, Unless Excepted Sometimes Required Optional
• Proper shipping name
• U.N. Identification Number
• Name and address of consignor or
consignee, unless:
-Highway only and no motor carrier
transfers, or
-Part of truckload lot and entire
contents of freight container are
shipped from one consignor to one
consignee (§172.301(d))
• If in excess of 50 kg, Gross Weight
• If hazardous substance, “RQ” in
association with the proper shipping
name
• The package type if Type A or Type B
(1/2” or greater letters)
• The specification-required markings
(see §178.350-353)
• For approved packages, the certificate
ID number
• Both the name and address of
consignor and consignee are
recommended.
• Other markings (e.g.,
advertising) are permitted, but
must be sufficiently away from
markings and labeling
Some Special Considerations for Marking Requirements
• Marking is required to be (1) durable, (2) printed on a package, label, tag, or sign, (3) unobscured by labels or
attachments, (4) isolated from other marks, and (5) be representative of the hazmat contents of the package.
• Limited quantity packages (§173.421) must bear the marking “radioactive” on the outside of the inner package, or the
outer package itself, and are excepted from other marking.
• Empty (§173.428) and Radioactive Instrument and Article (§173.424) packages are excepted from marking.
DOT Shipping Papers (49 CFR 172.200-205)
NOTE: IAEA, ICAO, and IMO may require additional hazard communication information for international shipments. This table must
not be used as a substitute for the DOT and NRC regulations on the transportation of radioactive materials.
Always Required, Unless Excepted Sometimes Required
• The basic description, in sequence
Proper shipping name
Hazard Class (7)
U.N. Identification Number
• 24 hour emergency response telephone number
• Name of shipper
• Proper page numbering (Page 1 of 4)
• The total quantity (mass), in appropriate units
• The name of each radionuclide and total package activity.
The activity must be in SI units (e.g., Bq, TBq) or both SI
units and customary units (e.g., Ci, mCi).
• For each labeled package:
- The category of label used
- The transport index of each package with a Yellow-II or
Yellow-III label
- Shipper’s certification (not required of private carriers)
• If hazardous substance, “RQ” as part of the basic
description
Optional
• The type of packaging (e.g., Type B)
• Other information is permitted (e.g., functional
description of product), provided it does not confuse or
detract from the proper shipping name or other required
information
• Emergency response hazards and guidance information
(§§172.600-604) may be entered on the shipping papers,
or may be carried with the shipping papers
Some Special Considerations/Exceptions for Shipping Paper Requirements
• Shipments of Radioactive Material, excepted packages, under UN2908-UN2911 (e.g., Limited Quantity, Empty, or
Instrument and Article), are excepted from shipping papers. For limited quantities (§173.421), this is only true if the
limited quantity is not a hazardous substance (RQ) or hazardous waste.
• Shipping papers must be in the pocket on the left door, or readily visible to a person entering the driver’s compartment and
within arm’s reach of the driver.
• For shipments of multiple cargo types, any HAZMAT entries must appear as the first entries on the shipping papers, be
designated by an “X” (or “RQ”) in the hazardous material column, or be highlighted in a contrasting color.
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Appendix O
Daily Maintenance Check of
Radiographic Equipment
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Daily Maintenance Check of Radiographic Equipment
A. The radiographer or radiographer’s assistant shall perform a daily maintenance check of the exposure device
and related radiographic equipment. This inspection will be performed before using the equipment on each
day the equipment is to be used. Report defective equipment to the RSO immediately! Do not attempt to
use defective equipment. After the inspection, document the results of the inspection.
1. Inspect the survey meter for battery check, zero and operation. If batteries are low, replace, then check for
operability. If not able to correct a problem with the survey meter, obtain another meter and start over.
2. Check survey meter with a check source (which should give a reading of _______ millirem) (or check
at a specific location on the camera _______ which should give a reading of _____ millirem) as
indicated on the survey meter. If reading is not acceptable, obtain another meter and start again.
Note: RSO or calibration vendor should determine the acceptable meter reading for each survey meter and post the
expected reading on each instrument. This reading shall be obtained and noted at the time of calibration.
3. Inspect the remote-control radiographic equipment as follows:
Inspect the cables for cuts, breaks, and broken fittings.
Carefully inspect approximately one foot of the drive cable immediately next to the male connector.
Take care not to introduce any dirt or dust on the drive cable during this inspection. In addition to the
previously mentioned items, the examination of the cable should look for any of the following:
- Excessive or uneven wearing;
- Fraying;
- Unraveling;
- Nicks;
- Kinks or bends;
- Loss of flexibility (abnormal stiffness);
- Excessive grit or dirt;
- Stretching;
- Inspect the crank unit for damage and loose hardware;
- Check operation of the control for freedom of drive cable movement;
- Inspect the guide tube for cuts, crimps, and broken fittings;
- Survey for radiation levels and record readings. The radiation levels should be about the same
as those in the previous day's inspection, unless there has been a source change;
- Check that all safety plugs are in place;
- Inspect the exposure device for damage to fittings, lock, fasteners, and labels; and
- Check for any impairment of the locking mechanism.
4. Record the results of the daily inspection.
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Appendix P
Model Emergency Procedure
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Model Emergency Procedure
If the source fails to return to the shielded position or if any other emergency or unusual situation arises (e.g.,
vehicle accident, off-scale dosimeter, etc.)
Immediately secure the area and post the restricted area at the 0.02 mSv/hr (2 mrem/hr) radiation
level; maintain continuous surveillance and restrict access to the restricted area.
Notify the RSO and/or Management Personnel.
Take no further actions until instructions are received from the RSO.
Do not attempt source retrieval until the situation has been discussed with the RSO or other
knowledgeable personnel.
Don't panic. Source retrieval can be performed with very little exposure when properly planned by
trained personnel authorized to do so by a specific license.
Notify the persons listed below of the situation, in the order shown.
Name* Work Phone Number* Home Phone Number*
* Fill in with (and update, as needed) the names and telephone numbers of appropriate personnel (e.g., the
Radiation Safety Officer (RSO), or other knowledgeable licensee staff , licensee's consultant, device
manufacturer) to be contacted in case of emergency. Update information as necessary.
Follow the directions provided by the person contacted above.
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 123
RSO and Licensee Management
Discuss emergency operating procedures, and ensure no operations are conducted until the situation has been
discussed with and approved by the RSO or other knowledgeable staff, consultants, or device manufacture.
Management should have access to emergency equipment to keep doses to radiographers ALARA. Emergency
equipment may include high range dosimeters, extra lead shielding, remote tongs, etc.
Notify local authorities as well as KYDPH as required. KYDPH notification is required when sources or
devices containing licensed material are lost or stolen and when radiographic sources or equipment are involved
in incidents that may have cause or threatens to cause an exposure in excess of 902 KAR 100:019 limits.
Reports to KYDPH must be made within the reporting time frames specified by 902 KAR 100:019, 902 KAR
100:040, 902 KAR 100:100.
Telephone notifications shall be made to KYDPH at (502) 564-3700 during normal business hours (8 a.m.
– 4:30 p.m.). For immediate notifications after normal business hours, KYDPH’s 24 hour emergency
telephone number is (800) 255-2587. Identify the emergency as radiological.
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Appendix Q
Annual Low-Level Waste Reporting Requirements
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 125
Kentucky Administrative Regulation 902 KAR 100:21, Section 12 requires each holder of a specific radioactive
material license to annually file a report with KYDPH regarding radioactive waste associated with activities
authorized by the license.
The report shall be filed no later than January 15 of the year following the reporting period, whether that
licensee was or was not a low level radioactive waste (LLRW) or radioactive mixed hazardous waste generator
during the calendar year reporting period. Further information can be found at the Kentucky legislative
Research Website at http://www.lrc.ky.gov/kar/TITLE902.HTM.
LLRW is only waste material which contains any regulated level of radioactivity, whether man made or
naturally occurring. Radioactive material (RAM) becomes a waste when the generator has removed the RAM,
and items contaminated with RAM, from the process or procedure in which it was used or produced, and
segregated for disposal. Even though many licensees do not produce such LLRW materials, the LLRW
form must be completed and returned every year by the licensee. Furthermore, any facility that was just
granted a license in the current calendar year must also complete a LLRW Report.
Information regarding any radioactive mixed waste in your possession must also be reported. Radioactive
mixed waste contains both radioactive waste and a hazardous waste. Examples of hazardous waste include
organic solvents, metallic lead, mercury, chromate, cadmium, aqueous corrosive liquids, waste oils, and
halogenated cleaning/degreasing wastes (i.e., wastes that are subject to the Resource Conservation and
Recovery Act (RCRA)).
Disposal data submitted by Kentucky licensees must agree with records compiled by the disposal sites. This
information is required by the Central Midwest Compact, which Kentucky and Illinois entered for the disposal
of low-level waste, pursuant to the Federal Low-Level Waste Policy Act of 1985 (http://www.cmcompact.org/)
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 126
ANNUAL LOW LEVEL RADIOACTIVE WASTE (LLRW) REPORT
REPORTING PERIOD – CALENDAR YEAR 20__ __
Kentucky Radiation Health Branch 275 East Main Street
Mail stop HS 1C-A
Frankfort, KY 40621
FAX: 502 564-1492
TEL: 502 564-3700
1. Licensee Information
Facility Name:
License Number:
Mailing Address:
Address where LLRW stored and/or held for decay in storage (if different from above)
In calendar year 20__ __ stated above, this license was (check one):
_____ newly granted _____ active all year _____ terminated
Person’s responsible for low level radioactive waste management
Name: Title:
Phone Number: ( )
Person responsible for completing LLRW annual report
Name (printed): Title:
Phone Number: ( )
2. Did this licensee possess or dispose of any low level radioactive waste (LLW) during this reporting
period? _____ Yes _____ No
NOTE: Return of nuclear medicine radioactive materials back to the originating pharmacy is considered
a transfer of radioactive material and not waste generation or waste shipment for the purposes of
this report. The same is true of sealed sources and devices returned to the manufacturer.
3. Did this licensee possess or dispose of any mixed radioactive waste during this reporting period? _____
Yes _____ No
4. Does this licensee currently possess any LLW in storage? _____ Yes _____ No
NOTE: This does not apply to medical wastes held in accordance with 902 KAR 100:072, Section 29.
IF YOUR RESPONSE WAS “NO” TO QUESTIONS #2, #3 AND #4 ABOVE,
COMPLETE ITEM #14 AND RETURN THIS FORM
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 127
ANNUAL LOW LEVEL RADIOACTIVE WASTE (LLRW) REPORT
REPORTING PERIOD – CALENDAR YEAR 20__ __
5. If yes to question 4, provide the following information, as defined in 902 KAR 100:021,
Section 6 (2), Classes of Waste.
STORED RADIOACTIVE WASTE
As defined in 902 KAR 100:021, Section 6 (2)
CLASS A CLASS B CLASS C
Volume (Cubic Feet)
Volume (Cubic Feet)
Volume (Cubic Feet)
Volume (Cubic Feet)
Volume (Cubic Feet)
Volume (Cubic Feet)
6. Which method(s) of disposal of LLW are used by your facility?
(IF MORE THAN ONE METHOD OF DISPOSAL IS USED, RANK THE METHODS
NUMERICALLY, ACCORDING TO VOLUME OF WASTE)
_____ Decay in storage _____ Ship directly to LLW disposal site
_____ Sanitary sewer _____ Use of LLW broker for final disposal
_____ Return to supplier _____ Other (specify)
_____ Dilution via air effluent
7. If radioactive waste was shipped directly to a disposal site or via a broker during this reporting period
complete the following. (One 55 gallon drum is equivalent to 7.5 cubic feet)
SHIPPED DIRECTLY TO: CUBIC FEET ACTIVITY (Millicuries)
Richland, WA ____________ __________
Barnwell, SC ____________ __________
Envirocare, UT ____________ __________
Other ____________ __________
Via Broker ____________ __________
8. If a broker was utilized during this reporting period, indicate name, address and telephone number
Broker name Tel. ( )
Address
City/State/Zip
KYREG-IR Kentucky Industrial Radiography License Guide, Revised 08/2013 128
ANNUAL LOW LEVEL RADIOACTIVE WASTE (LLRW) REPORT
REPORTING PERIOD – CALENDAR YEAR 20__ __
9. What were the five (5) isotopes with the highest activity disposed directly or via a broker at a disposal site?
10. Indicate by percentage the classification of the LLW, as defined in 902 KAR 100:021, Section 6 (2),
shipped or stored for shipment:
Class A __________ Class B ___________ Class A___________
Greater than Class C __________
11. Do you have any LLW in storage for future shipment, directly or via a broker, to awaste disposal site?
Yes _____ No ______
12. If you have mixed waste in storage, or shipped mixed waste during the reporting period, please provide
the following information.
Volume
(cu.ft.)
Physical form
(i.e. solid, liquid)
Radionuclides
present
Activity
(mCi)
13. Describe your plans for treatment, disposal or storage of mixed waste.
14. I hereby certify that the information provided is true and correct to the best of my knowledge and belief.
(*Must be signed by someone with Signature Authority for license)
*Signature Title
Type/Printed Name Date